The Association of University Export Control Officers (AUECO) submitted comments regarding the U.S. Department of Commerce’s proposed amendments to export controls on end-use and end-user activities, particularly those relating to military and intelligence applications. While AUECO welcomed provisions that clarify regulatory requirements and exclude low-risk academic activities from unnecessary controls, the organization expressed significant concern over ambiguities in the proposed definitions of “Military-Support End User” (MSEU) and “Intelligence End User” (IEU). Specifically, AUECO urged the Bureau of Industry and Security (BIS) to retain explicit exclusions for routine academic activities from the definition of “support” to prevent inadvertent violations and confusion within academic contexts.
AUECO cautioned that the broad and unclear definitions of MSEU and IEU could unintentionally classify organizations, such as large universities with minimal military or intelligence-linked projects, as restricted entities, severely hindering benign academic and research collaborations. They recommended that BIS modify the relevant language to focus on entities whose principal or direct activities materially contribute to military or intelligence objectives, and suggested mechanisms such as expedited advisory processes and clear guidance documents for exporters. The association also highlighted the risk of overly burdensome regulations chilling international education and research, and called for a balanced approach that protects national security without undermining the collaborative ethos essential to U.S. scientific and technological leadership. The comment letter was endorsed by the Council on Government Relations (COGR).
