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On 15 January 2025, Minister for Foreign Trade and Development Reinette Klever notified Parliament and published in the Government Gazette (Staatscourant) that the Netherlands would expand its national export-control measure — the Besluit Strategische Goederen (Strategic Goods Decree) national-authorisation architecture — to cover a new category of advanced semiconductor manufacturing equipment: specific measuring and inspection (metrology) systems.
Technical scope. The new measure covers optical and e-beam systems capable of detecting defects at 21 nm and below — the yield-management and process-verification layer critical to producing advanced-node chips. This is structurally distinct from the prior DUV lithography controls (TWINSCAN NXT:1970i/1980i, filed 2024-09-07) and the original 2023 immersion-DUV regime: metrology/inspection equipment sits at a different step in the semiconductor manufacturing flow (post-exposure process verification, defect detection, CD metrology) and involves a different supplier base. Key affected companies are ASML's Hermes Microvision (HMI) subsidiary — which manufactures e-beam inspection systems in San Jose and Veldhoven — and ASM International (ASMI, Almere) for ALD/CVD process-monitoring equipment.
Licensing architecture. The national licence requirement applies to exports to ALL destinations outside the EU — not just China. Per-shipment approval by the Centrale Dienst voor In- en Uitvoer (CDIU, Dutch Customs) in conjunction with the Ministry of Foreign Affairs (BUZA) and Ministry of Economic Affairs (EZ). ASML will apply for Dutch government licences for this equipment category rather than US Department of Commerce (BIS) licences, mirroring the architecture already established for DUV lithography.
Policy rationale. Minister Klever cited increased security risks from the combination of Dutch metrology equipment with technologies from other countries to produce advanced semiconductors usable in advanced military applications. This framing explicitly positions the measure as a national-security unilateral control rather than a multilateral export-control regime (the Wassenaar Arrangement does not specifically control most metrology equipment at these specifications).
The Netherlands has now built three distinct export-control layers for its semiconductor-equipment cluster:
1. Immersion DUV lithography (2023-06-30) — TWINSCAN systems; triggered by US pressure post-October 2022 BIS advanced-logic controls; effective September 2023. 2. DUV capacity expansion (2024-09-07) — added TWINSCAN NXT:1970i and NXT:1980i to close a loophole in the 2023 measure; effective March 2024. 3. Metrology and inspection (this action, 2025-01-15) — extends the national-licence architecture to the defect-detection and yield-management equipment layer; effective April 2025.
Together, the three layers correspond to the three pillars of advanced-node semiconductor production that the US BIS Foreign Direct Product Rule targets: exposure (lithography), yield management (metrology/inspection), and deposition/etch (partially addressed via ASMI controls). The Dutch unilateral architecture now substantially parallels US BIS controls on the same equipment cohort.
high-ASP tools (>$50mn per unit); licences required for every non-EU shipment from April 2025. Chinese customers (SMIC, YMTC, CXMT, Huawei HiSilicon foundry ecosystem) are the primary demand segment affected.
is included; affects ASMI's China exposure (China accounted for ~26% of ASMI 2024 revenue).
non-substitutable bottleneck: without yield feedback from optical scatterometry (KLA/ASML) and e-beam inspection (HMI), sub-5nm process development cannot iterate. This makes the metrology layer arguably more control-sensitive than throughput-capacity lithography expansion.
non-EU-wide), the April 2025 measure's licensing scope is explicitly all non-EU destinations, including US-allied purchasers such as TSMC (Taiwan) and Samsung (South Korea). Dutch licences are expected to be granted routinely for allied destinations; the practical effect is targeted at China.
specification thresholds beyond the 21-nm defect-detection capability criterion.
equipment scope (analogous to prior DUV guidance letters).
unilateral action often precedes multilateral alignment by 12-18 months.