ITI: Unilateral Approach to Semiconductor Export Controls Will Weaken U.S. Competitiveness, Not Achieve National Security Objectives
WASHINGTON – Today, global tech trade association ITI highlighted the potential economic consequences of a unilateral approach to restricting semiconductor exports. In comments (opens in a new tab) to the U.S. Department of Commerce Bureau of Industry and Security (BIS) on an Interim Final Rule (IFR) involving export controls on semiconductors, ITI urged BIS to work with industry to tailor export controls to technologies that pose a serious national security threat to the United States and to align controls with the multilateral export control regimes, avoiding unilateral applications. ITI encourages the U.S. government to work closely with companies to understand the intended—and unintended—consequences of such significant regulatory changes and allow appropriate time for companies to come into compliance with new and complex rules.
ITI emphasized that U.S. semiconductor companies earn over 80 percent of their revenue from sales to foreign markets, and semiconductors are America’s fourth largest export. Both U.S. and non-U.S. headquartered companies’ ability to participate in the global economy enables them to reinvest earnings into research and development and in the United States economy.
“The unilateral approach… is a primary concern for ITI and our member companies. Despite public assurances from senior U.S. officials that allied nations will follow suit, ITI has significant concerns regarding the status of such negotiations and the potential for a true multilateral approach. Unilateral controls limit the ability of companies to participate in the global marketplace and in turn disrupt the virtuous cycle of private-sector R&D investments made possible by revenues from sales of U.S. products to a diverse customer base in overseas markets,” ITI wrote in the comments. “A thorough, timely, and ongoing evaluation of foreign availability and capability must also inform consideration of new or amended regimes. In cases where technology of comparable quality, quantity, and cost is available outside the U.S., controls will be ineffective in preventing end users of concern from acquiring the controlled technology and will weaken U.S. global competitiveness.”
ITI has been a consistent, engaged contributor and thought partner with BIS on semiconductor manufacturing and supply chain issues. ITI’s 2023 Tech Policy Roadmap for U.S. Competitiveness and Growth (opens in a new tab) recommend that the U.S. Congress and the Biden Administration work to quickly provide semiconductor incentive grants and promptly establish the National Semiconductor Technology Center with non-discriminatory corporate governance rules for research and development, while avoiding new mandates that would slow implementation and work against increasing America’s semiconductor manufacturing capacity.
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