COGR Submits Response to Interim Final Rule—“Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners”

COGR submitted a formal response to the U.S. Department of Commerce Bureau of Industry and Security's interim final rule regarding the implementation of export controls on advanced technologies. COGR acknowledges the necessity of safeguarding sensitive technologies amid evolving global threats and supports efforts to align U.S. regulations with those of international partners, while also emphasizing the importance of maintaining international research collaborations that drive scientific advancement. The organization expresses appreciation for the Bureau's engagement with stakeholders and its attempts to mitigate regulatory burdens, particularly as they pertain to deemed export procedures. However, COGR raises concerns about the prospect of a quantum-specific deemed export licensing policy, arguing that such a measure could unnecessarily complicate the compliance process for research institutions. The organization strongly reaffirms its support for the preservation of the fundamental research exclusion (FRE), which allows institutions to conduct and share fundamental research without excessive administrative constraints. COGR underscores that maintaining the FRE is essential for fostering innovation, supporting national security and public health, and developing a skilled science and technology workforce. The response concludes with a willingness to engage further with the Bureau on these critical issues.