The MATCH Act aims to harmonize export controls on certain semiconductor manufacturing equipment (SME) by requiring toolmaking allies to match U.S. restrictions within 240 days. The STRIDE Act would provide the foundation for allied coordination on implementing export controls across the semiconductor value chain.
Together, the MATCH Act and STRIDE Act aim to sweep in allied-origin research, design, manufacturing, materials, equipment, and subsystems and components, covering the full semiconductor supply chain.
The Current Status of U.S. Dual-Use Export Controls: Rules and Gaps in Coordination
In the United States, export controls over SME are authorized under the Export Administration Regulations (EAR) issued by the Department of Commerce’s Bureau of Industry and Security (BIS), an administrative procedure. This means the controls are subject to executive discretion and can be amended at any time. Aside from the short-lived “Affiliates Rule,” BIS has not rolled out any additional export control rules on the semiconductor supply chain since the beginning of the second Trump administration.
Currently, the EAR’s destination and end-user control coverage operates on parallel tracks: (1) country-wide controls and (2) Entity List controls—which require the administration to add to or remove from the Entity List. In the case of SME controls, BIS applies country-wide restrictions on certain advanced equipment, while requiring licenses for less advanced tools. BIS reviews the latter on a case-by-case basis.
Moreover, although EAR’s extraterritorial reach through the Foreign Direct Product Rule (“FDP Rule”) extends U.S. controls over foreign items using American-origin technology, regulatory alignment with allies is pursued diplomatically and informally, through negotiations and U.S. regulatory leverage. For example, the United States negotiated a deal with Japan and the Netherlands in 2023 to harmonize export controls on certain SME. As a result, all three countries aligned their export controls by blocking the most advanced models of deep ultraviolet immersion (DUVi) lithography equipment from being sold to the People’s Republic of China (PRC). This meant that the United States would cease to enforce the FDP Rule on DUVi lithography equipment, leaving Japan and the Netherlands to review licenses on such tools. However, the Dutch ban went into effect a year after the deal was reached, allowing Chinese firms to stockpile DUVi equipment. Additionally, the export control rules of each participant currently focus on the sale of new equipment, meaning that many DUVi lithography systems already inside the PRC can still be maintained, repaired, and supplied with spare parts.
Congress intends to address these shortcomings through the MATCH Act and STRIDE Act.
The MATCH Act and the STRIDE Act
The MATCH Act
The MATCH Act attempts to codify pre-existing export controls on SME, meaning that controls cannot be negotiated away by any presidential administration. The bill directs relevant agencies, including the Departments of Commerce and State, in coordination with the Departments of Defense and Energy, to identify “key chokepoint” SME (i.e., electrostatic chucks, DUV light sources, radio frequency power generators, impedance-matching networks, optics, lasers) and the semiconductor manufacturing facilities of entities within countries of concern (the PRC, including Hong Kong and Macau; Iran; North Korea; the Russian Federation; and any other country listed in Country Group D:5 of the EAR).
Following the identification report, agency heads have 120 days to rally allied SME supplier countries to adopt country-wide controls on chokepoint equipment for all countries of concern and presumption-of-denial licensing for exports, transfers, and servicing to key facilities in countries of concern. If allies do not adopt such controls within 240 days following the enactment of the MATCH Act, BIS must impose U.S. controls over the key chokepoint SME and semiconductor manufacturing facilities and conduct reviews of servicing licenses.
Additionally, the MATCH Act, if passed, would require BIS to update the EAR in the following aspects.
First, it would establish (and require allies to follow suit) a country-wide presumption of denial for a wider universe of SME, potentially limiting the number of SME available to the PRC. After reviewing key chokepoint SME, BIS may need to create additional Export Control Classification Numbers to reflect the tools that current controls do not cover. Furthermore, the MATCH Act would broaden controls to include country-wide restrictions, rather than individualized Entity List designations. This would eliminate the administrative lag associated with placing certain entities on the Entity List.
Second, it would bar all servicing (including installation, calibration, repair, firmware updates, and training) of applicable items at key semiconductor manufacturing facilities located within countries of concern. This provision would close the most significant operational gap in the current EAR, whereby China can maintain existing advanced allied tools even after new sales are cut off.
Third, it would convert the informal carve-out system for allied alignment into a statutory extraterritorial framework with a hard deadline—replacing diplomatic discretion with legislative compulsion.
The STRIDE Act
In contrast to the MATCH Act’s snapback mechanism for non-cooperative allies, the STRIDE Act aims to create an institutional framework for allied cooperation through diplomatic coordination and reporting statutes, led by the State Department. The STRIDE Act recognizes the need for broader controls over the semiconductor value chain and coordination with allies to harmonize controls.
The bill pursues the following objectives:
Aligning export controls on SME and critical subcomponents
Expanding restrictions on design tools, IP transfers, servicing, and technical assistance
Conducting joint monitoring and enforcement against export control circumvention and “foreign backfilling”
Sharing information on transfer risks, insider threats, and end-user verification
Securing trusted supplier networks
Reviewing the effectiveness of existing and proposed controls, including assessing the economic impact of such controls
Harmonizing approaches against the outflow of semiconductor technologies via foreign direct investment, talent flight, and espionage
The objectives of the STRIDE Act highlight a regulatory gap in the current EAR and an enforcement shortfall in the current regime, both requiring allied cooperation. This broad inclusion aims to address the PRC’s export control “workaround” strategy, which increasingly targets materials supply chains rather than finished equipment.
Conclusion
Export controls on SME, materials, and subsystems and components are important instruments for restraining the PRC’s ambitions to achieve AI compute performance competitive with leading American chips—leveraging advanced packaging to compensate for restricted access to leading-edge process nodes—and dominate critical industries such as the foundational chip market. The MATCH Act and the STRIDE Act take meaningful steps in the right direction by aiming to codify SME export controls and harmonize allied controls on the semiconductor value chain.
The specifics of these two bills may be subject to change as they move along the legislative process. At the very least, HFAC’s advancement of a record number of export control bills signals that Congress is adopting a clear stance on export controls, as the Trump administration exhibits ambivalence. American policymakers should build upon this momentum to enshrine export controls as a critical component of economic security.
Narrowing the Gap Through MATCH and STRIDE: A Primer on Recent Export Control Bills
作者：Sylvia Chen、Peter Tozzi
2026-06-30
Introduction
In late April, the House Foreign Affairs Committee (HFAC) advanced the Multilateral Alignment of Technology Controls on Hardware Act (H.R. 8170) (“MATCH Act”) and the Semiconductor Technology Resilience, Integrity, and Defense Enhancement Act (H.R. 6058) (“STRIDE Act”), along with 20 other export control bills. These bills are now eligible for a vote by the full House. These two proposed bills complement each other but operate at different levels.
The MATCH Act aims to harmonize export controls on certain semiconductor manufacturing equipment (SME) by requiring toolmaking allies to match U.S. restrictions within 240 days. The STRIDE Act would provide the foundation for allied coordination on implementing export controls across the semiconductor value chain.
Together, the MATCH Act and STRIDE Act aim to sweep in allied-origin research, design, manufacturing, materials, equipment, and subsystems and components, covering the full semiconductor supply chain.
The Current Status of U.S. Dual-Use Export Controls: Rules and Gaps in Coordination
In the United States, export controls over SME are authorized under the Export Administration Regulations (EAR) issued by the Department of Commerce’s Bureau of Industry and Security (BIS), an administrative procedure. This means the controls are subject to executive discretion and can be amended at any time. Aside from the short-lived “Affiliates Rule,” BIS has not rolled out any additional export control rules on the semiconductor supply chain since the beginning of the second Trump administration.
Currently, the EAR’s destination and end-user control coverage operates on parallel tracks: (1) country-wide controls and (2) Entity List controls—which require the administration to add to or remove from the Entity List. In the case of SME controls, BIS applies country-wide restrictions on certain advanced equipment, while requiring licenses for less advanced tools. BIS reviews the latter on a case-by-case basis.
Moreover, although EAR’s extraterritorial reach through the Foreign Direct Product Rule (“FDP Rule”) extends U.S. controls over foreign items using American-origin technology, regulatory alignment with allies is pursued diplomatically and informally, through negotiations and U.S. regulatory leverage. For example, the United States negotiated a deal with Japan and the Netherlands in 2023 to harmonize export controls on certain SME. As a result, all three countries aligned their export controls by blocking the most advanced models of deep ultraviolet immersion (DUVi) lithography equipment from being sold to the People’s Republic of China (PRC). This meant that the United States would cease to enforce the FDP Rule on DUVi lithography equipment, leaving Japan and the Netherlands to review licenses on such tools. However, the Dutch ban went into effect a year after the deal was reached, allowing Chinese firms to stockpile DUVi equipment. Additionally, the export control rules of each participant currently focus on the sale of new equipment, meaning that many DUVi lithography systems already inside the PRC can still be maintained, repaired, and supplied with spare parts.
Congress intends to address these shortcomings through the MATCH Act and STRIDE Act.
The MATCH Act and the STRIDE Act
The MATCH Act
The MATCH Act attempts to codify pre-existing export controls on SME, meaning that controls cannot be negotiated away by any presidential administration. The bill directs relevant agencies, including the Departments of Commerce and State, in coordination with the Departments of Defense and Energy, to identify “key chokepoint” SME (i.e., electrostatic chucks, DUV light sources, radio frequency power generators, impedance-matching networks, optics, lasers) and the semiconductor manufacturing facilities of entities within countries of concern (the PRC, including Hong Kong and Macau; Iran; North Korea; the Russian Federation; and any other country listed in Country Group D:5 of the EAR).
Following the identification report, agency heads have 120 days to rally allied SME supplier countries to adopt country-wide controls on chokepoint equipment for all countries of concern and presumption-of-denial licensing for exports, transfers, and servicing to key facilities in countries of concern. If allies do not adopt such controls within 240 days following the enactment of the MATCH Act, BIS must impose U.S. controls over the key chokepoint SME and semiconductor manufacturing facilities and conduct reviews of servicing licenses.
Additionally, the MATCH Act, if passed, would require BIS to update the EAR in the following aspects.
First, it would establish (and require allies to follow suit) a country-wide presumption of denial for a wider universe of SME, potentially limiting the number of SME available to the PRC. After reviewing key chokepoint SME, BIS may need to create additional Export Control Classification Numbers to reflect the tools that current controls do not cover. Furthermore, the MATCH Act would broaden controls to include country-wide restrictions, rather than individualized Entity List designations. This would eliminate the administrative lag associated with placing certain entities on the Entity List.
Second, it would bar all servicing (including installation, calibration, repair, firmware updates, and training) of applicable items at key semiconductor manufacturing facilities located within countries of concern. This provision would close the most significant operational gap in the current EAR, whereby China can maintain existing advanced allied tools even after new sales are cut off.
Third, it would convert the informal carve-out system for allied alignment into a statutory extraterritorial framework with a hard deadline—replacing diplomatic discretion with legislative compulsion.
The STRIDE Act
In contrast to the MATCH Act’s snapback mechanism for non-cooperative allies, the STRIDE Act aims to create an institutional framework for allied cooperation through diplomatic coordination and reporting statutes, led by the State Department. The STRIDE Act recognizes the need for broader controls over the semiconductor value chain and coordination with allies to harmonize controls.
The bill pursues the following objectives:
The objectives of the STRIDE Act highlight a regulatory gap in the current EAR and an enforcement shortfall in the current regime, both requiring allied cooperation. This broad inclusion aims to address the PRC’s export control “workaround” strategy, which increasingly targets materials supply chains rather than finished equipment.
Conclusion
Export controls on SME, materials, and subsystems and components are important instruments for restraining the PRC’s ambitions to achieve AI compute performance competitive with leading American chips—leveraging advanced packaging to compensate for restricted access to leading-edge process nodes—and dominate critical industries such as the foundational chip market. The MATCH Act and the STRIDE Act take meaningful steps in the right direction by aiming to codify SME export controls and harmonize allied controls on the semiconductor value chain.
The specifics of these two bills may be subject to change as they move along the legislative process. At the very least, HFAC’s advancement of a record number of export control bills signals that Congress is adopting a clear stance on export controls, as the Trump administration exhibits ambivalence. American policymakers should build upon this momentum to enshrine export controls as a critical component of economic security.
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