The joint letter from five major academic associations—COGR, AAU, APLU, ACE, and AAMC—responds to the Department of Commerce’s Advance Notice of Proposed Rulemaking on the review of controls for certain emerging technologies, as mandated by the Export Control Reform Act of 2018 (ECRA). These organizations, representing the U.S.'s leading research universities and medical schools, express fundamental support for the government’s effort to safeguard national security by assessing which emerging technologies warrant export controls. They commend the explicit preservation of "fundamental research" in the proposed rule, underscoring the necessity of maintaining an open research environment to facilitate scientific progress and international collaboration.
The associations urge the Bureau of Industry and Security (BIS) to adopt a precise, policy-driven definition of emerging technologies, one that avoids ambiguity and overreach. They recommend that controls focus narrowly on developmental technologies of clear and specific national security significance, avoid encompassing foundational or widely available technologies, and not hinder academic research or the U.S. economy. The letter emphasizes the critical role of academic experts in ongoing advisory processes, calls for regulatory consistency with existing export control frameworks, and opposes vague or overly broad parameters. In conclusion, the associations advocate that any new controls should only be implemented when demonstrably essential to national security, and after robust, evidence-based consultation with stakeholders. They encourage multilateral rather than unilateral approaches to ensure balanced, effective, and internationally harmonized regulation.
This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).
