by Semiconductor Industry Association
SIA has long supported export control policy that safeguards national security without unduly harming the commercial innovation that is essential to America’s economy, national security, and technological leadership. Consistent with these longstanding efforts, SIA recently submitted detailed public comments regarding significant new semiconductor export control rules released on Oct. 7 by the Bureau of Industry and Security (BIS).
U.S. semiconductor companies are dependent on a “virtuous cycle” of innovation that includes large investments into research and development and access to global markets. Historically, U.S. semiconductor companies have consistently invested about one-fifth of their revenues in research and development, among the highest shares of any industry. As such, it is important to ensure export controls are aligned with the “small yard, high fence” paradigm. Therefore, the most effective export controls are those that are narrowly tailored to specific items and adopted on a multilateral basis, and which incorporate sufficient industry input before implementation, including on issues of foreign availability.
While SIA and its member companies fully understand targeted export controls are necessary to safeguard national security, the Oct. 7 export control rules are unprecedented in scope and detail, and create new challenges for the global semiconductor ecosystem. The SIA comments emphasize the following recommendations regarding the Oct. 7 export control rules:
Finally, SIA’s comments seek clarifications on specific provisions of the rule to facilitate industry compliance and avoid unnecessary business interruptions. SIA appreciates the opportunity to submit these comments and will continue to promote dialogue between the government and private sector.
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