The National Association of Manufacturers (NAM), which has been urging the current and previous administrations to modernize the export control system, has sent a letter to National Security Advisor General James Jones and National Economic Advisor Lawrence Summers outlining its recommendations for President Obama’s export controls review. The letter stresses the need to tighten controls on truly sensitive technology and simplify controls on technology that is not critical to national security—and is readily available from other countries.
The letter from John Engler, president of NAM, conveys that the U.S. export control system is not in sync with the realities of the 21st century and must be modernized to improve both U.S. security and global competitiveness. The NAM recommendations aim to help shape a 21st century export controls regime that enhances U.S. security, strengthens the defense industrial base, and does not serve as an export promotion program for our trade competitors.
“We believe our recommendations will strengthen national security, focus limited resources on truly sensitive technologies, promote U.S. technological and scientific leadership, and improve economic competitiveness,” Engler writes. “While these recommendations only focus on near and medium term improvements, the NAM also supports the Administration’s goal for fundamental reform. We will also provide a blueprint to the Administration on our vision for fundamental reform and creation of a new export control system for the 21st century in the near future.
“The NAM looks forward to working with the interagency team to improve the export control system by making it more predictable, transparent, and efficient and welcomes the opportunity to discuss our recommendations with the review team.”
The NAM recommendations focus on the following areas:
1. Improving the licensing system and increasing transparency
2. Providing greater assessments of foreign availability
3. Reviewing and restructuring encryption rules and policy
4. Conducting a systematic review of the Commerce control list
5. Promoting greater multilateral cooperation with our friends and allies
6. Enhancing the Commerce Department’s role in the commodity jurisdiction process
7. Improving outreach cooperation on enforcement
8. Improving outreach to and resources for small and medium-sized manufacturers.
The detailed NAM Recommendations for Improving Dual-Use Export Controls are available online.