F-22Raptor
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The primary U.S. export control target to constrain competitors’ AI capabilities
should be the semiconductor manufacturing equipment (SME) necessary to
manufacture high-end chips. Slowing the growth of China’s high-end semiconductor
manufacturing ability, coupled with continued U.S. investments in microelectronics
R&D, will set back China’s attempts to catch up to the United States and its allies,
and force it to continue to rely on foreign firms to supply its high-end
semiconductors. While constraining China’s chip manufacturing capability does not
inherently restrict China’s ability to acquire high-end chips, it would force China to
rely more on U.S. and allied firms for such production, which would provide the
United States with significant leverage over China’s future capabilities.
There are four primary reasons SME makes an ideal target for export controls to
limit China’s future AI capabilities:
1. Compute is key to AI - AI is becoming increasingly reliant on compute over
time,166 even as its application becomes more widespread. These two forces
demonstrate that high-end semiconductors will be essential to power many
future AI applications.
2. China will likely remain reliant on high-end semiconductor imports - In
2016, semiconductors were China’s largest import, totaling over $200
billion,167 and it does not have significant domestic production capability for
chips below 14nm.168 However, it has invested heavily in the semiconductor
field to grow its domestic supply chain and become an industry leader by
2030, with the ultimate goal of decreasing or eliminating its reliance on
foreign hardware.169 From 2014 to 2018, China was the world’s largest
importer of SME, accounting for 29 percent of global imports.170
3. High-end SME is very specialized - In particular, extreme ultraviolet (EUV)
lithography tools, the most advanced photolithography technology, are
necessary for producing chips at the 7nm node and below and cost $120
million, weigh 180 tons, and require 20 trucks or three fully loaded Boeing
747s to ship.171 The complex nature, rarity, and size of this equipment makes
it difficult to replicate or steal.
4. U.S. Allies control the SME market - The manufacturers of SME are
concentrated within a very small geographic group of allied nations. In 2017,
the eight largest SME firms were located in the United States, Japan, and the
Netherlands.172 These three countries also contained over 90 percent of the
global SME industry in 2015.173
Photolithography tools, the most complex and expensive type of SME, are even more
concentrated than SME writ large, with one active Dutch company (ASML) and two
active Japanese companies (Nikon and Canon).174 Furthermore, ASML has a
monopoly over EUV lithography tools. ASML also has a dominant 88 percent
market share in ArF immersion photolithography tools, the next most advanced
photolithography technology, necessary for chips from the 7nm to 45nm node.
Nikon is the only other supplier of ArF immersion photolithography tools.175
Recommendation 5: The United States should work with the
Netherlands and Japan to restrict the export of EUV and ArF immersion
lithography equipment to China, and take steps to increase demand for
such tools among U.S. firms.
The United States must work in cooperation with the Netherlands and Japan to
prohibit the export of EUV and ArF Immersion lithography equipment to China, in
order to restrict China’s semiconductor production capability at the 45nm node and
below, which the Commission assesses to be the chips most useful for advanced AI
applications.176 Although Chinese firms do have existing production capability down
to 14nm at limited scale, China’s ability to manufacture photolithography equipment
capable of production below the 90nm node is significantly more limited. If these
controls are effective, it would be very difficult for China to obtain any new high-end
lithography equipment, and any repairs or maintenance on existing equipment
would likely prove difficult. While chips 45nm and below currently present the most
utility for advanced AI applications and are the most feasible to control, this standard
will also have to be continuously reevaluated to ensure controls are capturing the
proper equipment and not unnecessarily harming industry.
Given Dutch and Japanese companies are the sole suppliers of EUV and ArF
Immersion lithography equipment, these two governments have the collective ability
to significantly reduce China’s ability to produce high-end semiconductors. In 2019,
the United States reportedly put significant pressure on the Netherlands to block a
sale of EUV lithography equipment from ASML to SMIC. These efforts proved
successful, as ASML ultimately let the contract expire without delivering the
equipment.177 The United States should double down on such efforts, while also
encouraging Japan to restrict China’s access to ArF Immersion equipment.178
Furthermore, the United States should set a clear policy goal of remaining two
generations ahead of China in state-of-the-art microelectronics fabrication
capabilities by utilizing a combination of export controls and substantial commercial
R&D investment.179 In support of this goal, the United States should initiate a
simultaneous effort to provide tax credits or subsidies to U.S. firms that purchase
semiconductor manufacturing equipment, to include EUV and ArF Immersion
lithography equipment from Dutch or Japanese firms, to support efforts to build
advanced foundries in the United States. This program, which would require
Congressional authorization, could partially assuage concerns from the governments
of the Netherlands and Japan about the financial impact of controls on SME, while
simultaneously working to revitalize the semiconductor manufacturing base in the
United States. This credit could also be coupled with additional initiatives, such as a
federal match program for existing state and local incentives, and tax credits for
efforts to study and reduce the potential environmental impact of semiconductor
facilities. Combined, these incentives would further efforts to grow diverse U.S. high-
end microelectronics fabrication capabilities. This would complement the recent,
encouraging announcements by TSMC that it intends to build a state-of-the-art
fabrication facility in the United States,180 and would also benefit other firms
exploring similar proposals.181
The “CHIPS for America Act,” a bipartisan, bicameral bill introduced by Senators
John Cornyn (R-TX) and Mark Warner (D-VA), as well as by Representatives
Michael McCaul (R-TX) and Doris Matsui (D-CA), includes such a tax credit for
SME, along with several other investments which seek to revitalize the U.S.
semiconductor manufacturing base.182 This Commission supports this bill, which
incorporates several of the Commission’s first quarter recommendations focused on
maintaining U.S. leadership in high-end microelectronics that are key to AI,
including by funding research for next generation microelectronics technologies and
creating a national laboratory and incubator dedicated to establishing U.S.
leadership in microelectronics packaging and manufacturing. The Commission
believes the CHIPS Act would create a more competitive U.S. market for
semiconductors, revitalize the broader U.S. microelectronics industrial base,
incentivize firms to bring additional elements of the manufacturing process back to
the United States, and ensure the United States retains global leadership in advanced
microelectronics research and development.
An excerpt from the US National Security Commission on Artificial Intelligence
should be the semiconductor manufacturing equipment (SME) necessary to
manufacture high-end chips. Slowing the growth of China’s high-end semiconductor
manufacturing ability, coupled with continued U.S. investments in microelectronics
R&D, will set back China’s attempts to catch up to the United States and its allies,
and force it to continue to rely on foreign firms to supply its high-end
semiconductors. While constraining China’s chip manufacturing capability does not
inherently restrict China’s ability to acquire high-end chips, it would force China to
rely more on U.S. and allied firms for such production, which would provide the
United States with significant leverage over China’s future capabilities.
There are four primary reasons SME makes an ideal target for export controls to
limit China’s future AI capabilities:
1. Compute is key to AI - AI is becoming increasingly reliant on compute over
time,166 even as its application becomes more widespread. These two forces
demonstrate that high-end semiconductors will be essential to power many
future AI applications.
2. China will likely remain reliant on high-end semiconductor imports - In
2016, semiconductors were China’s largest import, totaling over $200
billion,167 and it does not have significant domestic production capability for
chips below 14nm.168 However, it has invested heavily in the semiconductor
field to grow its domestic supply chain and become an industry leader by
2030, with the ultimate goal of decreasing or eliminating its reliance on
foreign hardware.169 From 2014 to 2018, China was the world’s largest
importer of SME, accounting for 29 percent of global imports.170
3. High-end SME is very specialized - In particular, extreme ultraviolet (EUV)
lithography tools, the most advanced photolithography technology, are
necessary for producing chips at the 7nm node and below and cost $120
million, weigh 180 tons, and require 20 trucks or three fully loaded Boeing
747s to ship.171 The complex nature, rarity, and size of this equipment makes
it difficult to replicate or steal.
4. U.S. Allies control the SME market - The manufacturers of SME are
concentrated within a very small geographic group of allied nations. In 2017,
the eight largest SME firms were located in the United States, Japan, and the
Netherlands.172 These three countries also contained over 90 percent of the
global SME industry in 2015.173
Photolithography tools, the most complex and expensive type of SME, are even more
concentrated than SME writ large, with one active Dutch company (ASML) and two
active Japanese companies (Nikon and Canon).174 Furthermore, ASML has a
monopoly over EUV lithography tools. ASML also has a dominant 88 percent
market share in ArF immersion photolithography tools, the next most advanced
photolithography technology, necessary for chips from the 7nm to 45nm node.
Nikon is the only other supplier of ArF immersion photolithography tools.175
Recommendation 5: The United States should work with the
Netherlands and Japan to restrict the export of EUV and ArF immersion
lithography equipment to China, and take steps to increase demand for
such tools among U.S. firms.
The United States must work in cooperation with the Netherlands and Japan to
prohibit the export of EUV and ArF Immersion lithography equipment to China, in
order to restrict China’s semiconductor production capability at the 45nm node and
below, which the Commission assesses to be the chips most useful for advanced AI
applications.176 Although Chinese firms do have existing production capability down
to 14nm at limited scale, China’s ability to manufacture photolithography equipment
capable of production below the 90nm node is significantly more limited. If these
controls are effective, it would be very difficult for China to obtain any new high-end
lithography equipment, and any repairs or maintenance on existing equipment
would likely prove difficult. While chips 45nm and below currently present the most
utility for advanced AI applications and are the most feasible to control, this standard
will also have to be continuously reevaluated to ensure controls are capturing the
proper equipment and not unnecessarily harming industry.
Given Dutch and Japanese companies are the sole suppliers of EUV and ArF
Immersion lithography equipment, these two governments have the collective ability
to significantly reduce China’s ability to produce high-end semiconductors. In 2019,
the United States reportedly put significant pressure on the Netherlands to block a
sale of EUV lithography equipment from ASML to SMIC. These efforts proved
successful, as ASML ultimately let the contract expire without delivering the
equipment.177 The United States should double down on such efforts, while also
encouraging Japan to restrict China’s access to ArF Immersion equipment.178
Furthermore, the United States should set a clear policy goal of remaining two
generations ahead of China in state-of-the-art microelectronics fabrication
capabilities by utilizing a combination of export controls and substantial commercial
R&D investment.179 In support of this goal, the United States should initiate a
simultaneous effort to provide tax credits or subsidies to U.S. firms that purchase
semiconductor manufacturing equipment, to include EUV and ArF Immersion
lithography equipment from Dutch or Japanese firms, to support efforts to build
advanced foundries in the United States. This program, which would require
Congressional authorization, could partially assuage concerns from the governments
of the Netherlands and Japan about the financial impact of controls on SME, while
simultaneously working to revitalize the semiconductor manufacturing base in the
United States. This credit could also be coupled with additional initiatives, such as a
federal match program for existing state and local incentives, and tax credits for
efforts to study and reduce the potential environmental impact of semiconductor
facilities. Combined, these incentives would further efforts to grow diverse U.S. high-
end microelectronics fabrication capabilities. This would complement the recent,
encouraging announcements by TSMC that it intends to build a state-of-the-art
fabrication facility in the United States,180 and would also benefit other firms
exploring similar proposals.181
The “CHIPS for America Act,” a bipartisan, bicameral bill introduced by Senators
John Cornyn (R-TX) and Mark Warner (D-VA), as well as by Representatives
Michael McCaul (R-TX) and Doris Matsui (D-CA), includes such a tax credit for
SME, along with several other investments which seek to revitalize the U.S.
semiconductor manufacturing base.182 This Commission supports this bill, which
incorporates several of the Commission’s first quarter recommendations focused on
maintaining U.S. leadership in high-end microelectronics that are key to AI,
including by funding research for next generation microelectronics technologies and
creating a national laboratory and incubator dedicated to establishing U.S.
leadership in microelectronics packaging and manufacturing. The Commission
believes the CHIPS Act would create a more competitive U.S. market for
semiconductors, revitalize the broader U.S. microelectronics industrial base,
incentivize firms to bring additional elements of the manufacturing process back to
the United States, and ensure the United States retains global leadership in advanced
microelectronics research and development.
An excerpt from the US National Security Commission on Artificial Intelligence