The document is a detailed comment letter from Katharina Phillips, President of the Council on Governmental Relations (COGR), responding to recommendations by the U.S. Department of Commerce Inspector General (IG) regarding deemed export controls and their application to university fundamental research. The letter expresses the concerns of COGR, representing 160 research-intensive U.S. universities and affiliated institutions, about the potential adverse impacts of implementing the IG's recommendations. COGR argues that such measures, which would require extensive export licensing for foreign nationals' access to controlled research equipment and technology, are founded on misunderstandings of both the fundamental research exclusions currently in export regulations and the operational realities of academic research settings. The organization contends that the proposed changes would make U.S. universities less attractive to international students and scholars, thus harming both national security and economic competitiveness by stifling innovation and reducing the diversity and quality of research talent.
COGR supports maintaining the current reliance on visa and classification processes for security screenings, and it opposes redefining the distinction between public and controlled research in a way that would dramatically expand compliance burdens. The letter emphasizes that separating the products and processes of academic research is impractical, as technology transfer and equipment use are inherently intertwined in university environments. The organization provides evidence that the proposed licensing requirements would impose massive administrative and financial burdens on universities, potentially costing millions of dollars and requiring tens of thousands of person-hours annually for compliance. COGR further raises constitutional and practical objections to basing export control requirements on a person’s country of birth rather than citizenship. Instead, it advocates for greater regulatory clarity, a precise definition of "use technology," and a sustained dialogue among government, academia, and industry stakeholders to ensure policy decisions strike an appropriate balance between security and the open, collaborative nature of scientific research. The letter concludes with endorsements of similar positions advocated by other leading academic and scientific associations.
