The US-China Business Council (USCBC) is pleased to provide comments on the Department of Commerce’s Advance Notice of Proposed Rulemaking (ANPRM) on Review of Controls for Certain Emerging Technologies. USCBC represents over 200 American companies who operate in a diverse range of industries and employ millions of Americans.
We appreciate the notice’s emphasis on avoiding “negatively impacting US leadership in the science, technology, engineering, and manufacturing sectors” in identifying emerging technologies that should be subject to new export controls. We agree it is critical that updates to US export controls be implemented “without impairing national security or hampering the ability of the US commercial sector to keep pace with international advances in emerging fields.” Keeping this goal in mind, USCBC recommends that the list of technologies covered by any new rules be narrowly tailored to address US national security interests, with the support of multilateral regimes, and without stifling US businesses.
In addition to specific industry comments, which can help set the proper scope for the final controls, USCBC encourages relevant US government agencies to consider the broader commercial implications of listing certain products as “emerging and foundational technologies” subject to new export controls.