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MEMA Joins Manufacturing and Tech Associations Calling for Longer Comment Period of New Export Control Rule

Date: July 1, 2019

The Motor & Equipment Manufacturers Association (MEMA) joined 26 other manufacturing and technology organizations urging the Secretary of Commerce Wilbur Ross to provide a 90-day comment period to respond to the anticipated Advance Notice of Proposed Rulemaking (ANPRM) regarding the review of controls for foundational technologies set forth in the Export Control Reform Act of 2018 (ECRA).

In a June 27 letter addressed to Secretary Ross, MEMA and the other cosigners maintain that 90 days are needed to ensure that impacted associations and their members “have adequate time to review the notice and provide comprehensive feedback to address the policy concerns and technological complexities at issue.”  

“The development of industry input in response to the emerging technologies ANPRM provided a window into the complex dimensions of these proposed policy changes,” the letter said. “We thank you for recognizing those challenges and graciously extending the timeframe for interested parties to respond.”

In addition to MEMA, those signing the letter include the Alliance of Automobile Manufacturers, the Association of Global Automakers, Consumer Technology Association, and the National Association of Manufacturers.

Commerce is updating export controls after Congress passed a law last year requiring an update to the export control regime on “emerging” and “foundational” technologies. Commerce is seeking information from the public to determine if stricter controls are needed, if, for example, the emerging or foundational technologies contribute to potential conventional weapons, intelligence collection, weapons of mass destruction, or terrorist applications or other national security concerns. While “foundational” technologies have not been defined, the “emerging” technologies ANPRM identified a list of technologies such as artificial intelligence, nanotechnology, navigation technology, robotics and advanced materials. MEMA submitted comments in December in response to the emerging technologies ANPRM.

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