SMEE (Shanghai Micro Electronics Equipment)

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Shanghai Micro Electronics Equipment (Group) Co., Ltd., known as SMEE, is China's best known photolithography equipment maker and its designated national champion in the field. It was founded in Shanghai in 2002, is controlled by state shareholders, and has built lithography systems for chip packaging, displays, LEDs, MEMS and compound semiconductors alongside laser annealing, wafer bonding and optical inspection tools [1][2]. Since a 2025 restructuring it is meant to concentrate on front-end lithography research, with the packaging business held by a separate company [7]. It has been on the US Bureau of Industry and Security Entity List since December 2022 [3].

SMEE is the company most often named when people ask whether China can build its own alternative to ASML. That question is not academic for artificial intelligence. Chinese AI accelerators are designed domestically but printed on equipment that is largely foreign and increasingly export-controlled, so the ceiling on how much AI compute China can build without American permission is set in a lithography bay, not a design house. Huawei's Ascend parts are fabricated by SMIC on a deep ultraviolet multi-patterning flow precisely because extreme ultraviolet tools are unavailable, and every proposal for a domestic replacement runs through SMEE or through companies built out of it. Lithography is the one gap in China's semiconductor industry that four years of rapid progress in etch, deposition, cleaning and metrology has not closed.

The gap between that reputation and SMEE's actual shipping record is the useful thing to establish. SMEE's revenue has come overwhelmingly from back-end and non-leading-edge tools, not from the front-end scanners it is famous for. Its most advanced front-end machine addresses 90nm. Almost every dramatic claim about a domestic 28nm scanner traces to an unnamed source, a deleted social media post or a securities newsletter, and several have been retracted. In 2025 the company was split apart: its commercially successful packaging business was spun into a separate firm, and its immersion deep ultraviolet programme was transferred to a different company entirely. The sections below set out who asserted what, on what date, and what happened to the claim afterwards.

Founding, ownership and control

SMEE was established in Shanghai in 2002, which EqualOcean records as coinciding with the inclusion of lithography research in China's National High-tech R&D Programme, the 863 Programme [4]. It was set up under the Shanghai Electric group, and He Rongming, a former Shanghai Electric vice president, served as general manager and then chairman from 2002 until early 2018 [4]. Gan Pin, previously a vice director at the Shanghai Science and Technology Committee, became chairman afterwards [4].

The company became a designated vehicle of the 02 Special Project (02专项), the national science and technology megaproject for integrated circuit manufacturing equipment announced in China's 2006 medium and long-term science plan [4]. That is the funding channel through which most of its front-end lithography work has been done, and it explains why SMEE's milestones are announced as project acceptances by government committees rather than as product launches.

SMEE is not listed on any exchange and publishes no financial statements, which is why almost every revenue, order-book and shipment figure attributed to it online is unverifiable. Its registered address, as recorded by BIS, is No. 1525 Zhangdong Road in the Shanghai pilot free trade zone, in the Zhangjiang high-technology park in Pudong [3][5].

Ownership is state-dominated but distributed across several Shanghai municipal vehicles rather than held by a single parent. TrendForce described SMEE in December 2025 as an affiliate of Shanghai Electric Group [6], and the South China Morning Post describes it simply as state-owned [7]. The one shareholding disclosed by a listed company is Zhangjiang Hi-Tech (Shanghai Stock Exchange 600895), which told the market in September 2025 that it holds 10.78 percent of SMEE through its wholly owned subsidiary Shanghai Zhangjiang Haocheng Venture Capital, from an initial investment of about RMB 223 million [8]. Detailed shareholder tables circulating on Chinese retail investment sites, typically giving Shanghai Electric Holding Group a stake of roughly 32 percent, are not traceable to a company filing and are not repeated here as fact.

Rumours that SMEE would reach the public market through a reverse merger into a listed shell circulated widely in September 2025 and were reported as market chatter, not as company disclosure [8]. As of August 2026 no such transaction has been announced.

Product line

SMEE's own English website organises the business into four groups: lithography equipment, integrated circuit derivative products (laser annealing and wafer bonding), flat panel display derivative products (photo alignment and measurement), and optical metrology and inspection [1].

There is a naming inconsistency worth flagging before reading any coverage of the company. SMEE's site labels its front-end step-and-scan family the SSX600 series [9], while trade press and analysts almost always call the same 90nm ArF tool the SSA600 or SSA600/20 [4][10]. TrendForce reports that the SS prefix denotes step-and-scan, with the third letter distinguishing the family; the KrF system awarded a government contract in December 2025 carries an SSC designation [6]. Treat SSX600, SSA600 and 600 series as the same product family.

FamilySegmentStated capabilityEvidence status
SSX600 / SSA600 seriesIC front-end step-and-scan90nm, 110nm and 280nm critical and non-critical layers on 8-inch or 12-inch lines, per SMEE's own site [9]Project acceptance announced 2018 [2]; no confirmed volume sales [10]
SSA800 seriesIC front-end immersion28nm single exposure, smaller nodes via multi-patterningDesign transferred out of SMEE in 2025; not launched by SMEE [11]
SSC800/10IC front-end step-and-scan, KrF248nm source, 110nm resolution, 15nm overlay, dry (not immersion)Sole-source government contract December 2025 [6]
SSB500 seriesAdvanced packaging stepperFlip chip, fan-in and fan-out wafer- and panel-level packaging, 2.5D and 3D integration [12]First unit delivered December 2009 [2]; commercially established [10]
SSB300 seriesCompound semiconductor, micro and mini LED, MEMSSmall-substrate lithography [1]Named a national "manufacturing single champion" product in 2019 [2]
SSB200 / SSB225 / SSB245Flat panel display exposureSSB225/10 for 2.5-generation AM-OLED TFT circuitsSSB225/10 delivered 2013; SSB245 won a gold award in 2016 [2]
SLD seriesLaser annealingIC derivative productListed on SMEE's site [1]
SOI500 / SOI600 / SOI800Optical metrology and inspectionIC, FPD, LED, MEMS, power devicesListed on SMEE's site [1]

The lithography families above the packaging line are the ones that draw attention. They are not the ones that have paid the bills.

Where the revenue actually comes from

The AI Futures Project's June 2026 assessment of Chinese lithography, written by Hamish Low, Joshua Turner and Romeo Dean, is blunt about SMEE's commercial record: the company "has only ever sold i-line tools in any sustained way," had "brief success with a KrF tool in the early 2010s, generating about $50 million in revenue before it was discontinued for lack of interest," and its 90nm ArF tool, the SSA600, "was prototyped in 2011, but has not achieved commercial sales since" [10]. Where SMEE has succeeded, the same report says, is behind the leading edge: it "has created commercially viable back-end lithography machines used for packaging at mature nodes (>90 nm)" [10].

That matches the market share figures. EqualOcean reported in June 2021 that SMEE held over 80 percent of the domestic and nearly 40 percent of the global market in back-end advanced packaging lithography, plus roughly 20 percent in LED, MEMS and power device lithography, with customers including SMIC, Hua Hong Semiconductor, YMTC and GTA Semiconductor [4]. The same analysis put SMEE's front-end technology roughly a decade behind ASML's, and identified optical systems and light sources as the supplier gaps that stood between it and a 28nm-capable machine [4].

Advanced packaging is not a consolation prize in an AI context. Chiplet assembly, 2.5D interposers and the stacking used for high-bandwidth memory are among the few routes to more usable compute per die that do not require a smaller transistor, and they are the routes China can currently take. But packaging lithography is a different engineering problem from a 28nm immersion scanner, and success at one says little about the other.

The 2025 restructuring: AMIES and the Yuliangsheng transfer

SMEE in 2026 is not the company it was in 2024. Two separations happened within about a year, and together they moved both its commercial base and its most advanced front-end programme outside the corporate entity.

AMIES Technology was founded in Shanghai in February 2025 as a spin-off from SMEE, taking the packaging and derivative equipment business with it [7][12]. AMIES exhibits compound semiconductor lithography systems, laser annealing tools, inspection equipment and packaging and wafer bonding solutions, and announced the shipment of its 500th stepper in August 2025 [12]. The company claims its advanced packaging lithography machine holds about 35 percent of the global market and around 90 percent of the Chinese market, figures that are AMIES's own and have not been independently audited [12]. The South China Morning Post, reporting on the new company in October 2025, noted that its most advanced production-grade tools address processes around the 90nm node and above, and that the 2023 claim of 28nm capability had been retracted [23]. In January 2026 AMIES took full ownership of Shanghai Weiyao Industrial, a SMEE subsidiary handling metal component and materials processing, becoming sole shareholder with committed capital of RMB 228.5 million (about US$32 million) [7][13]. The South China Morning Post described the effect as leaving SMEE "concentrated more heavily on the 'front-end' development of lithography tools" while AMIES handles commercialisation [7], and TrendForce framed the split as AMIES retaining back-end packaging and inspection while SMEE retains front-end lithography research and development including EUV [13].

The export control asymmetry is the part that matters legally. SMEE is on the Entity List; AMIES, incorporated more than two years after that designation, is not listed. That gap is discussed in the export controls section below.

The immersion DUV transfer. Asia Times reported in July 2026 that SMEE passed the technology of the SSA800 immersion scanner to Shanghai Yuliangsheng in 2025, together with the engineers who built it, while keeping its own extreme ultraviolet project [11]. Yuliangsheng is a 2022 joint venture of SiCarrier and the state-backed Chuangkewei (Shanghai) Technology; its engineering team subsequently moved into Shanghai Aishengna Electronic Technology Group, a state-owned vehicle incorporated in August 2023 with RMB 7 billion of registered capital [11]. Asia Times put the current arrangement plainly: Yuliangsheng, SMEE and Aishengna "are actually sharing the same team of engineers, who are developing a machine similar to SMEE's SSA800" [11].

This is the single most garbled fact in coverage of Chinese lithography. The SSA800 is SMEE's design. Reporting that attributes the immersion scanner to SiCarrier is wrong: SiCarrier is a co-owner of a joint venture whose engineers now work inside a third company, and it has never publicly shown a lithography tool of its own.

Front-end lithography: the 90nm and 28nm record

The 90nm tool

SMEE's own milestone page records that the 90nm lithography machine project was officially accepted in 2018, and that the 600 series IC front-end scanner won a silver award at the 20th China International Industry Fair the same year [2]. Its product page states that the SSX600 series meets front-end requirements for 90nm, 110nm and 280nm critical and non-critical layers on 8-inch or 12-inch production lines [9].

Two things are being conflated when this is reported as a shipping product. Acceptance under the 02 Special Project is a government committee signing off that a development contract has been met. It is not evidence of qualified production tools running in a commercial fab. The AI Futures Project's position, that the SSA600 was prototyped in 2011 and has not achieved commercial sales since, is the strongest sourced claim about volume [10]. Against it, TrendForce reported in November 2025 that "SMEE's self-developed 600 series lithography system has entered mass production at the 90nm node and is now developing a 28nm immersion model" [14].

Those two statements cannot both be right, and neither is supported by a public order book. The safest reading, and the one this article adopts, is that SMEE has a working 90nm ArF front-end platform that has been accepted by its government sponsor and is described by Chinese trade press as in production, but that no independent evidence of sustained commercial front-end shipments has been published. Anyone citing a unit count for the 600 series is citing something untraceable.

The 28nm claims

The 28nm story is a chain of announcements, none of which has yet ended in a verified commercial tool. The chain is set out in full because most readers will arrive having seen at least one link in it.

DateClaimOriginWhat happened
2020 to early 2021SMEE would achieve 28nm mass production capability by the first quarter of 2021Chinese online reports, no named company sourceNever materialised
August 2023The first domestically produced SSA/800-10W lithography machine would be delivered to the market by the end of 2023Securities Daily, relayed by Global Times; SMEE did not respond to interview requests [15]No delivery confirmed
December 2023SMEE had "successfully developed a 28nm lithography machine," the SSA/800-10WWeChat post by the account "Hello Zhangjiang," run by SMEE shareholder Zhangjiang Group [16]Post revised within days to say the company was merely "committed to developing advanced lithography machines," removing the achievement claim [16]
December 2025A large government lithography contract was read as confirmation of a 28nm toolProcurement notice, amplified onlineVerified by Chinese outlet ICsmart as a KrF system with 110nm resolution, not 28nm [6]
2025 to 2026Widely repeated specification sheets stating that an SSA800-10W was delivered to SMIC in early 2025 with 1.9nm overlay and multi-patterning capability to 11nmNo identifiable primary source; the figures propagate through aggregator sites and forumsNot corroborated by any named outlet or company statement

The last row deserves the explicit treatment the rest of this article gives to sourced claims: those numbers are widely circulated and, as of August 2026, unsourced. They are recorded here so that readers who have seen them know that the trail ends in aggregators.

The reference point that gets lost in each cycle is how old the target node is. TSMC had been running 28nm since 2011 and SMIC since 2015, both on ASML equipment [16].

The SSA800 and who owns the design

The SSA800 is the designation SMEE has used for its next-generation immersion ArF platform, targeting 28nm in a single exposure and smaller features through multi-patterning [17]. As of mid-2026 SMEE had never officially launched it, and it no longer builds it.

The machine now in limited production is built by Shanghai Aishengna using the transferred SMEE design and the combined Yuliangsheng and SMEE engineering team [11]. The reported characteristics, all attributed rather than confirmed:

ItemReported figureSource
Reference pointRoughly equivalent to ASML's TWINSCAN NXT:1950i, launched 2008 for 28nmAnalysts cited by Asia Times, July 2026 [11]
Gap to ASMLAbout four generations, "roughly equivalent to the Dutch company's lithography tool from 15 years ago"Analyst quoted by Asia Times [11]
Domestic contentAbout 70 percentMedia reports cited by Asia Times [11]
Still importedZeiss lenses, ArF immersion light source, 193nm excimer laser mirrorAsia Times [11]
Named domestic suppliersNanjing Wavelength Opto-Electronic, MLOptic, Changchun Institute of Optics, Fine Mechanics and PhysicsAsia Times [11]
Volume planAbout 5 units in 2026, about 20 in 2027The Information, relayed by Asia Times and Electronics Weekly [11][17]
First customersSMIC, Hua Hong Semiconductor, CXMTElectronics Weekly [17]
Customer trialSMIC evaluating a Yuliangsheng immersion tool since September 2025Financial Times, relayed by Asia Times [11]

Electronics Weekly noted that its own account of the shipment plan rested on unattributed sourcing, using "is said to" throughout, and that no throughput figure or foreign component list had been published [17]. Asia Times separately recorded that the Chinese outlet ICsmart called an online report of SSA800 mass production in January 2026, an exhibition in March and stable 90 to 95 percent yields groundless, saying the series had not entered a commercial wafer fab and appeared still to be in testing [11].

The December 2025 procurement award

On 25 December 2025 China's Ministry of Science and Technology awarded SMEE a sole-source contract for a step-and-scan lithography system. Single-source procurement in China is normally permitted only where irreplaceable patents or proprietary technology are involved, or where a public-service requirement forces a single supplier [6]. TrendForce put the value at about RMB 110 million; DigiTimes reported CNY 109 million, roughly US$15 million [6][18]. The size of the award, well above the low tens of millions of yuan typical of lithography tenders, fed a round of reporting that China had bought a 28nm machine.

It had not. The model is the SSC800/10, which ICsmart identified as a KrF system using a 248nm light source with 110nm resolution, and which MyDrivers described as a dry rather than an immersion tool with 15nm overlay accuracy [6]. A 110nm KrF scanner is a mature-node instrument. The episode is a clean illustration of the reporting pattern around SMEE: a real, documented, government-funded transaction, correctly reported by the outlets that checked the model number, and inflated everywhere else.

The EUV programme

SMEE kept its extreme ultraviolet work when it handed immersion DUV to Yuliangsheng in 2025 [11]. What that work amounts to is much less clear than the sentence suggests.

The verifiable elements are thin. SMEE has filed EUV-related patents, but the AI Futures Project's June 2026 assessment says only that the company "has posted a few EUV-related patents, but given its struggles to develop a viable DUV front-end tool, it is unclear to what extent EUV is even a priority" [10]. Chinese financial media reported that SMEE displayed a parameter chart for an EUV system at the 25th China International Industrial Fair in Shanghai on 23 September 2025, the first public appearance of anything EUV-related on its stand [8]. No resolution, overlay or throughput figures were published, SMEE issued no accompanying statement, and the brokerage commentary circulating alongside the reports described the effort as at a concept-verification stage rather than a working scanner.

China's better-documented EUV effort is not SMEE's. The AI Futures Project, summarising Reuters reporting from December 2025, records that China's prototype "can reportedly produce some EUV light, but remains far from producing working chips," that it relies on secondhand parts from ASML machines and from ASML's suppliers, and that the project "is run by the Chinese government itself, apparently with extensive involvement from Huawei" [10]. TrendForce reported in November 2025 that a laser-induced discharge plasma source, an alternative to the laser-produced plasma approach ASML uses, was being tested at a Huawei facility [14]. Neither line of work has been attributed to SMEE.

The AI Futures Project's base-rate modelling places commercial-scale Chinese EUV somewhere between 2037 and 2044 depending on method [10]. That forecast is the authors' own and is not independent market research.

US export controls

SMEE's regulatory history is one of the few parts of this subject that rests entirely on primary documents.

DateActionCitation
8 February 2022Added to the BIS Unverified List, with 32 other Chinese parties, because an end-use check could not be completed satisfactorily for reasons outside US government controlBIS final rule, 8 February 2022 [5]
16 December 2022 (published 19 December)Added to the Entity List; licence required for all items subject to the EAR, licence review policy of presumption of denial87 FR 77505 [3]
29 September 2025Affiliates Rule extends Entity List restrictions to any foreign entity 50 percent or more owned, directly or indirectly, by listed parties90 FR 47201 [19]
10 November 2025Affiliates Rule stayed until 9 November 202690 FR 50857 [20]

The Entity List entry reads "Shanghai Micro Electronics Equipment (Group) Co., Ltd., a.k.a., the following four aliases: Shanghai Microelectronics (Group) Co., Ltd.; Shanghai Micro Electronics Equipment Company; Shanghai Microelectronics Equipment Company; and SMEE," at No. 1525 Zhangdong Road, Pilot Free Trade Zone, Shanghai [3]. The End-User Review Committee's stated basis was that SMEE and the Shanghai Integrated Circuit Research and Development Center were "acquiring and attempting to acquire U.S.-origin items in support of China's military modernization," a risk finding under section 744.11(b) of the Export Administration Regulations [3]. The same rule added 36 entities in total, 35 in China and one in Japan, among them YMTC, the Shanghai Integrated Circuit Research and Development Center and a group of Cambricon entities [3].

Two qualifications belong with the designation. It is a risk determination, not a finding of wrongdoing adjudicated anywhere, and BIS published no supporting evidence beyond the rationale sentence. And it applies to the named legal entity: a company incorporated afterwards, holding transferred assets, is outside the entry unless BIS lists it or an ownership rule reaches it.

That is the AMIES question. AMIES Technology was incorporated in February 2025, more than two years after SMEE's designation, and as of August 2026 does not appear as a separately listed party. The Affiliates Rule of September 2025 would have swept in any entity 50 percent or more owned by SMEE [19], but BIS stayed that rule on 10 November 2025 until 9 November 2026 while it continues to evaluate the national security interests involved [20]. AMIES's ownership structure has not been published in a form that would settle whether the 50 percent threshold is met in any case. The practical position as of August 2026 is that the entity holding SMEE's commercially successful product lines is not itself subject to the Entity List restrictions that apply to SMEE.

For the wider framework, see Entity List and AI chip export controls.

Market position

A Nikkei Asia ranking of semiconductor equipment vendors by 2025 sales, reported by TrendForce in February 2026, placed SMEE twentieth globally, one of three Chinese firms in the top 20 alongside NAURA at fifth and AMEC at thirteenth [21]. The same analysis estimated that domestically made tools accounted for roughly 20 to 30 percent of equipment used in Chinese fabs, up from about 10 percent three years earlier [21]. TrendForce published no sales figure for SMEE, and the ranking predates the full effect of the AMIES separation, so it is unclear how much of the position it reflects belongs to the packaging business that has since left the company.

Two comparisons put the ceiling in perspective. The AI Futures Project credits ASML with 98.7 percent of the immersion lithography market and forecasts a commercially viable domestic Chinese 7nm-capable immersion scanner between 2032 and 2038, with a median of 2035 [10]. That forecast is the project's own estimate, not a market research finding, and the authors are explicit that what matters is not whether a machine can expose a wafer under controlled conditions but whether "large-scale commercial chip manufacturing happens" [10]. By their definition ASML's own EUV tools were pre-commercial from 2006 to 2019 [10].

SMEE exhibited under its own name at SEMICON China 2026, which opened in Shanghai on 25 March, alongside NAURA, AMEC, Piotech, ACM Research Shanghai and Hwatsing [22]. TrendForce reported no SMEE product announcement from the show.

Limitations and open questions

The company's public record is almost entirely announcements. SMEE is unlisted, files no accounts, rarely issues statements and did not respond to Global Times when a 28nm delivery was attributed to it [15]. Every widely cited financial figure for SMEE, including order books, revenue projections and unit shipment plans, originates on Chinese retail investment platforms rather than in any disclosure, and none of it is used in this article.

Project acceptance is not qualification. The 2018 90nm milestone was an 02 Special Project acceptance [2]. A front-end scanner becomes a real product only after months to years of joint qualification with a fab on real process data, and no such qualification record for SMEE's front-end tools is public.

The scanner is one item in a matched set. A domestic immersion tool does not remove the constraint on its own. Domestic Chinese producers hold under 1 percent of the KrF and ArF photoresist market, the EUV optics supply runs through Carl Zeiss SMT, in which ASML holds a 24.9 percent stake, and ASML acquired its light source supplier Cymer in 2013 [10].

The corporate perimeter keeps moving. In under two years SMEE has spun out its packaging business to AMIES, sold a subsidiary to AMIES, and transferred its immersion DUV programme and engineers to Yuliangsheng and then, in effect, to Aishengna [7][11][13]. Statements about "SMEE's capability" made before 2025 may now describe assets held by two other companies. Statements made about SiCarrier's lithography capability frequently describe SMEE's design.

Attribution errors run in both directions. Chinese state and social media have an incentive to present acceptance milestones as production breakthroughs; some Western coverage has an incentive to treat any Chinese tool announcement as an imminent threat; and the specific mechanism by which most bad claims enter circulation is a real document (a procurement notice, a patent, an award) read as evidence of something it does not say. The December 2025 KrF contract is the cleanest example [6].

Timeline

DateEvent
2002SMEE founded in Shanghai under the Shanghai Electric group, as lithography enters the 863 Programme [4]
December 2009First SSB500 advanced packaging stepper delivered [2]
2011SSA600 90nm ArF front-end tool prototyped; no commercial sales follow [10]
2013SSB225/10 delivered for 2.5-generation AM-OLED TFT circuit manufacturing [2]
2016SSB245 flat panel display exposure system wins a gold award [2]
Early 2018He Rongming leaves as chairman; Gan Pin succeeds him [4]
201890nm lithography machine project officially accepted; 600 series wins a silver award at the 20th China International Industry Fair [2]
2019SSB300 series named a national manufacturing single champion product [2]
8 February 2022Added to the BIS Unverified List [5]
16 December 2022Added to the US Entity List, presumption of denial for all items subject to the EAR [3]
August 2023Securities Daily reports an SSA/800-10W will be delivered by year end; SMEE does not comment [15]
December 2023Shareholder Zhangjiang Group's WeChat account claims a 28nm machine, then revises the post [16]
February 2025AMIES Technology spun off, taking the packaging and derivative equipment business [7][12]
2025SSA800 immersion DUV technology and engineers transferred to Shanghai Yuliangsheng; SMEE keeps its EUV project [11]
August 2025AMIES announces shipment of its 500th stepper [12]
23 September 2025SMEE shows an EUV parameter chart at the 25th China International Industrial Fair [8]
September 2025SMIC begins evaluating a Yuliangsheng immersion tool [11]
25 December 2025Ministry of Science and Technology awards SMEE a sole-source contract for an SSC800/10 KrF scanner, 110nm resolution [6]
January 2026AMIES acquires SMEE subsidiary Shanghai Weiyao Industrial for RMB 228.5 million [7][13]
25 March 2026SMEE exhibits at SEMICON China 2026 under its own name [22]
Late July 2026Limited production of the SMEE-designed immersion scanner reported at Shanghai Aishengna, with about 5 units planned for 2026 [11][17]

See also

References

  1. ^Shanghai Micro Electronics Equipment (Group) Co., Ltd., corporate website (English), accessed 1 August 2026. smee.com.cn/eis.pub
  2. ^SMEE, company milestones and product history page, accessed 1 August 2026. smee.com.cn/eis.pub
  3. ^Bureau of Industry and Security, "Additions and Revisions to the Entity List and Conforming Removal From the Unverified List," final rule, 87 FR 77505, published 19 December 2022, effective 16 December 2022, Docket 221209-0267, RIN 0694-AJ04. govinfo.gov/...2022-27151
  4. ^"Deep Dive: SMEE and China's Attempt to Replace ASML Tools," EqualOcean, 23 June 2021. equalocean.com/...2021062316392
  5. ^Bureau of Industry and Security, "Revisions to the Unverified List," final rule, published 8 February 2022 (full text). federalregister.gov/...2022-02536.txt
  6. ^"China's SMEE Reportedly Wins RMB 110M Lithography Tool Contract Amid Domestic Push," TrendForce, 26 December 2025. trendforce.com/...tool-contract-amid-domestic-push
  7. ^"China's top lithography bet shifts gears: SMEE sells subsidiary in strategic pivot," South China Morning Post, 7 January 2026. scmp.com/...-smee-sells-subsidiary-strategic-pivot
  8. ^"两连板张江高科,手握上海微电子超10%股权,还投资了这些企业," 21st Century Business Herald, 24 September 2025. 21jingji.com/...fea93849e27b92ac8b142847e4fd9143
  9. ^SMEE, SSX600 series product page, accessed 1 August 2026. smee.com.cn/eis.pub
  10. ^Hamish Low, Joshua Turner and Romeo Dean, "A forecast of Chinese DUV and EUV photolithography progress," AI Futures Project, 19 June 2026. blog.aifutures.org/...ecast-of-chinese-duv-and-euv
  11. ^"China's DUV lithography still lags ASML by four generations," Asia Times, 31 July 2026. asiatimes.com/...ill-lags-asml-by-four-generations
  12. ^"AMIES Rises in China's Lithography Push, Reportedly Capturing 90% of Domestic Market," TrendForce, 21 October 2025. trendforce.com/...-capturing-90-of-domestic-market
  13. ^"China's Lithography Push: AMIES Takes Full Shareholding in SMEE Subsidiary in Asset Restructuring," TrendForce, 7 January 2026. trendforce.com/...ubsidiary-in-asset-restructuring
  14. ^"Decoding China's Lithography Push to Challenge ASML: From SiCarrier to Alternative EUV Paths," TrendForce, 10 November 2025. trendforce.com/...carrier-to-alternative-euv-paths
  15. ^"Chinese firm expected to deliver 28nm chip machine at year-end: media report," Global Times, August 2023. globaltimes.cn/...1295484.shtml
  16. ^"Reports of SMEE Successfully Developing 28nm Lithography Machine, Original Source Deleted Shortly After," TrendForce, 22 December 2023. trendforce.com/...nal-source-deleted-shortly-after
  17. ^"Five DUV machines built by Shanghai Yuliansheng to ship this year," Electronics Weekly, 28 July 2026. electronicsweekly.com/...achines-this-year-2026-07
  18. ^"SMEE wins China lithography order, yet ASML still controls advanced-node tools," DigiTimes, 26 December 2025. digitimes.com/...overnment-manufacturing-equipment
  19. ^Bureau of Industry and Security, "Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities," interim final rule, 90 FR 47201, published 30 September 2025, effective 29 September 2025 (full text). federalregister.gov/...2025-19001.txt
  20. ^Bureau of Industry and Security, "One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities," 90 FR 50857, published 12 November 2025, staying the Affiliates Rule from 10 November 2025 to 9 November 2026 (full text). federalregister.gov/...2025-19846.txt
  21. ^"Three Chinese Chip Toolmakers Reportedly Enter Global Top 20 as NAURA Rises to Fifth by Sales," TrendForce, 2 February 2026. trendforce.com/...as-naura-rises-to-fifth-by-sales
  22. ^"Naura Reportedly Unveils Hybrid Bonding Tool at SEMICON China; SiCarrier, Last Year's Lithography Standout, Misses Show," TrendForce, 26 March 2026. trendforce.com/...lithography-standout-misses-show
  23. ^"Meet AMIES, China's new hope in breaking reliance on ASML's chipmaking machines," South China Morning Post, October 2025. scmp.com/...ing-reliance-asmls-chipmaking-machines

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Fact-checks are independent of edits: a reviewer re-verifies the article against its sources and stamps the date. How we verify

Reviewer note: Independently fact-checked on 2026-08-01. The Entity List addition effective 16 December 2022 and the earlier Unverified List entry of 8 February 2022 were both confirmed against the Federal Register, and the AMIES separation, its absence from the Entity List and the stay on the Affiliates Rule were verified independently. The article's decision to record the widely circulated SSA800-10W specification as having no identifiable primary source is sound and remains intact. Two corrections were applied to a capital figure and a date comparison.

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