ASML rejects EUV allegation: No lithography system or special components delivered to China

An EUV system does not disappear accidentally in a parcel center. It weighs approximately 180 tons, consists of around 100,000 individual parts, and requires multiple cargo aircraft, containers, and trucks for transport. Nevertheless, on 19 June 2026 ASML felt compelled to issue an unusually explicit clarification: the Dutch group had delivered neither a complete EUV lithography system nor components specifically developed for EUV systems to China. The trigger was a Bloomberg report according to which US Commerce Secretary Howard Lutnick is said to have expressed concern to ASML executives that one of the highly advanced systems or relevant technology could have reached China in contravention of Western export restrictions. No publicly accessible evidence for such an export has been presented to date. Two levels therefore initially stand opposed: on the one hand, according to the report, there are political concerns within the US government. On the other hand, there is a categorical denial from ASML. Anyone who already turns this into a proven circumvention of export controls is skipping the decisive part — the evidence.

What ASML specifically denies

ASML told Reuters that it had never shipped an EUV machine to China. In addition, no components, modules, or devices specifically developed for use in an EUV system had been delivered either. This wording is significant. It does not limit the denial to complete exposure systems, but, according to the company, explicitly also excludes assemblies intended for such use. ASML also emphasized that it had continuously adapted its business activities to new export rules. The group thus not only rejects the specific allegation, but also states in principle that it complies with the Western restrictions. The Dutch Foreign Ministry likewise referred to the applicable European and national dual-use regulations. Systems, components, and technologies covered by these rules require an export license. The Dutch authorities told Reuters that they enforce the rules strictly.

EUV is not the same as DUV

For proper classification, a clear distinction must be made between EUV and DUV. Over the years, ASML has delivered DUV lithography systems to China. These use deep ultraviolet light and are employed in numerous semiconductor processes. EUV, by contrast, works with light at a wavelength of 13.5 nanometers. The technology enables particularly small structures and is used for some of the most advanced logic chips. ASML is currently the only supplier of commercial EUV systems for mass production. EUV systems were never released for Chinese customers. Since 2023 and 2024, export rules for some particularly powerful DUV immersion systems have also been tightened. Therefore, the documented presence of ASML technology in Chinese factories does not automatically mean that EUV hardware is also present there. The distinction is sometimes handled imprecisely in political debates. China possesses numerous older and in some cases very powerful ASML systems. However, that is technically and regulatorily something different from possessing an EUV system. ASML itself describes an EUV system as the result of more than 20 years of development. A system contains approximately 100,000 individual parts. According to the manufacturer, delivery of one system requires around 40 freight containers, three cargo aircraft, and 20 trucks. In addition, there are highly specialized mirrors, vacuum technology, laser sources, metrology, software, and extensive installation at the customer’s site. The system is not rolled off a truck as a finished machine, but is transported in modules and assembled and calibrated on site. A complete export to China organized by ASML would therefore leave a considerable logistical, personnel, and documentary trail. This does not mean that individual industrial information or universally usable components could not in principle be transferred. But it does make the idea of a secretly delivered complete production system rather implausible. That is precisely why the more interesting question is not only a possible machine shipment.

What is more relevant is whether China can gradually build its own EUV architecture through former employees, in-house research, supplier knowledge, copied assemblies, or components with multiple uses. Reuters reported in December 2025 on a Chinese EUV prototype that is said to have been developed by a team including former ASML engineers. Sources described the project as a kind of Chinese “Manhattan Project” for advanced semiconductor manufacturing. Such a prototype is, however, not automatically an exported ASML system. China could reconstruct technical concepts through its own research, staff changes, publicly available patents, and the replication of individual functions. The decisive issue is whether this results in a system that achieves sufficient light output, precision, throughput, and reliability under industrial conditions. Generating an EUV source in the laboratory is already demanding. Even more difficult is a system that exposes wafers for months with high productivity and extremely low deviations. ASML’s lead therefore consists not only of a machine, but of a network built up over decades of optics, software, metrology, service, and suppliers. For the United States, China’s access to EUV technology is one of the most important issues in semiconductor export policy. Without modern EUV systems, cost-efficient mass production of some advanced chips is significantly more difficult. China can produce certain small structures via multiple patterning with DUV systems. However, this increases process steps, costs, error rates, and manufacturing effort. That is precisely why the United States, the Netherlands, and other partners seek to control not only complete EUV systems, but also advanced DUV systems, software, and maintenance services. The current concerns can therefore also be understood as preventive. Washington may want to ensure that no assemblies, knowledge, or indirect supply routes emerge before China announces its own technological breakthrough. That explains the political nervousness, but it does not replace evidence of a concrete export violation. It remains unclear what the alleged concerns of the US Commerce Secretary are specifically based on. The underlying report does not publicly name a serial number, a location, or an identified delivery. It is likewise unclear whether the concerns relate to a complete system, individual components, technical documentation, or China’s own prototype. ASML’s broad denial suggests that the company wanted to reject all of these delivery claims as clearly as possible. The US government initially did not comment on the Reuters report. Without further documents, the case therefore remains a politically relevant suspicion, but not a proven export of an EUV system.

Conclusion

I initially consider ASML’s denial to be much more credible than an unsubstantiated suspicion. A complete EUV system is too large, too complex, and too maintenance-intensive to show up in China like a suitcase with the wrong address label. Nevertheless, the case should not be dismissed prematurely. China’s progress in its own EUV research, the role of former ASML employees, and the significance of universally usable components are real issues. They are simply not the same as the alleged export of a complete Dutch machine. The actual race is probably no longer taking place at a customs terminal. It is taking place in laboratories, at suppliers, and in the knowledge of individual specialists — and is therefore much harder to control than a 180-ton system.

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