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NewsStructural3 min readDisconfirmAI Editorial

Former US Export Control Official Saif Khan: Stopping DUV Lithography Machine Exports Could Widen the China-US AI Chip Production Gap by 100x

Former US National Security Council and Department of Commerce official Saif Khan, in a ChinaTalk interview, introduced a report on DUV lithography machines released by his new think tank, the Center for Technology and Statecraft. The report argues that DUV immersion lithography is the most effective remaining control point in the competition for AI chip production capacity between China and the United States. If exports to China are halted, China's AI chip output could be only one percent of the US level by the mid-2030s; if exports continue, the uncertainty ranges of production capacity between the two countries may overlap, causing the US to lose its computing power leadership advantage.

2026-10-17 17:07 GMT+8

DUV immersion lithography machines are currently the most effective tool in the hands of the United States and its allies for controlling China's AI chip production capacity. Former US National Security Council and Department of Commerce official Saif Khan believes this tool is critical because China cannot manufacture it independently, and it is likely the hardest link in the entire semiconductor supply chain to achieve domestic substitution. He now leads the Center for Technology and Statecraft, which is part of the IFP think tank network. His team recently released an in-depth report exceeding 120 pages, which quantifies the impact of DUV export controls on the balance of AI computing power between China and the US through yield modeling, throughput analysis, and installed base calculations.

The core scenario presented in the report is as follows: By the mid-2030s, the US is expected to produce approximately one billion Nvidia H100-equivalent chips annually, with significant error margins. If DUV immersion lithography machine exports to China are stopped today, China's independent production capacity may cap at around ten million units per year, merely one percent of the US figure. Even if China mobilizes all resources, achieves domestic substitution in other supply chain links, and abandons smartphone chip production, capacity would only rise to the tens of millions range. Conversely, if exports continue, the uncertainty intervals of production capacity between the two countries may begin to overlap, potentially causing the US to lose its entire lead in computing power.

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This assessment is grounded in current regulatory loopholes. When controls were implemented in 2023, China had already installed approximately 170 to 180 DUV immersion lithography machines. Because some less advanced models were still permitted for export, this stockpile roughly doubled thereafter, significantly enhancing China's chip manufacturing capabilities. Saif Khan points out that even without sales to specific facilities, these equipment units can be easily diverted. Japan and the Netherlands are currently the sole producers of DUV immersion lithography machines. The report concludes that China will not possess commercialized domestic alternative tools until the mid-2030s, making this the most enduring and effective control lever in the US arsenal.

On the policy front, the US Congress is debating the MATCH Act, which addresses export controls on semiconductor equipment to China and includes potential restrictions on DUV immersion lithography machines. Saif Khan notes that while the export control policy direction of the Trump administration has seen adjustments, the AI Action Plan explicitly lists closing loopholes in semiconductor manufacturing equipment controls as a priority, and existing equipment controls have not been rolled back. He emphasizes that every additional day without implementing further controls surrenders a bit more leverage in shaping the China-US AI balance; however, this issue unfolds over a timespan measured in years, meaning that even if controls are enacted one or two years later, they will still have a significant long-term impact.

Sources

  • chinatalk.media↗
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