How China Got 340 DUVi Lithography Machines and Why We Should Stop Selling Them with Saif Khan and Nick Brown
Guest: Saif Khan and Nicholas Brown
About this episode
Saif Khan, founding director of the Center for Technology and Statecraft (CTS), and Nick Brown, CTS co-founder and senior fellow, join Gregory C. Allen to unpack their landmark 100+ page report, DUV Immersion Lithography: The Foundation of the US AI Advantage: Closing Gaps in Export Controls to China. Their central finding is that EUV gets the headlines, but the older immersion DUV machines are what China actually uses to make AI chips. China’s stockpile has grown from roughly 50–100 immersion tools in October 2022 to around 340 today. It imported about 90 a year in 2024 and 2025, close to two-thirds of ASML’s global immersion market.
They explain why ASML’s NXT:1980, which can be legally exported to China, is the machine to watch. They also cover how etch and deposition controls are masking the full power of China’s lithography stockpile, and why Chinese indigenization announcements, including the new 28nm prototype, don’t change the strategic picture before the 2030s. Then they lay out their scenario models. Even in an extreme case, China’s current stockpile can’t match US AI chip production through 2035, but continued imports could close the gap or even tip it. Finally, Saif and Nick make the case for a countrywide ban on immersion DUV, the levers the US could pull without new legislation, and what the MATCH Act in the Senate NDAA could mean for the fight.
Read the report at techstatecraft.org/duv.
In this episode
- 00:00Meet the Center for Technology and Statecraft and the people behind the report
- 05:35What immersion DUV is, and why it matters more than EUV for China’s AI chips
- 08:22From Cold War controls to ASML’s near-monopoly: how lithography export controls evolved
- 12:56The counterfactual: where would Huawei and SMIC be without EUV controls?
- 17:29Three tiers of DUV, the NXT:1980 loophole, and why countrywide beats case-by-case licensing
- 22:45What if the US had banned all immersion DUV in 2022? From 50+ machines to ~340
- 25:18Why China hasn’t yet unlocked the full power of its lithography stockpile
- 30:02Can China build its own? Prototype, commercialization, scale-up, and the 2030s
- 37:26The scenario models: when stockpile alone isn’t enough, and when imports tip the balance
- 45:40Flops per gigawatt, 90 machines a year, and 100,000 Huawei chips per tool
- 50:13Monday morning at BIS: allied controls, light sources, FDPR, de minimis, and the MATCH Act
- 55:11Where to find the report