The document is a joint comment submitted by leading academic associations—including the Council on Governmental Relations, Association of American Universities, Association of Public and Land-grant Universities, American Council on Education, and Association of American Medical Colleges—in response to the U.S. Department of Commerce Bureau of Industry and Security's Advance Notice of Proposed Rulemaking regarding the identification and review of controls for certain foundational technologies under RIN 0694-AH80. The associations, representing major U.S. research universities and medical schools, express support for national security objectives but emphasize the critical importance of maintaining open research environments and safeguarding the principle that fundamental research should remain largely unrestricted, as outlined in the Export Control Reform Act of 2018 and related directives.
In their recommendations, the associations urge caution against imposing overly broad or vague export controls that could inadvertently stifle scientific progress, impede academic collaboration, or undermine U.S. economic competitiveness. They advocate for controls to be narrowly tailored, consistent with established regulatory structures, and focused on specific end uses or end users rather than broadly applied list-based restrictions, especially given the global availability of many foundational technologies. The document also stresses the importance of academic representation in advisory processes, periodic review of imposed controls, and multilateral cooperation to ensure effectiveness and prevent disadvantaging U.S. entities. The overarching message is a call for balanced regulation that addresses specific security concerns without curtailing the openness and dynamism central to U.S. academic and scientific leadership.
This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies.
