WASHINGTON – Today, global tech trade association ITI offered recommendations to the U.S. government as it seeks to facilitate effective and practical U.S. and EU export controls cooperation under the Trade and Technology Council (TTC). In comments to the U.S. Commerce Department’s Bureau of Industry and Security (BIS), ITI outlined principles to guide the U.S. government’s engagement with the TTC’s Export Control Working Group and provided specific ways U.S. and EU officials can bolster collaboration on export controls.

“As the world’s leading innovation economies, the United States and EU have significant shared interests in aligning policy approaches in areas including export controls,” ITI wrote in its submission.The U.S. and EU should work collectively to ensure that any proposed export controls are targeted and tailored to the security threat at issue, agreed to at the multilateral level and do not detract from either economy’s leadership on innovative technologies.

ITI views the TTC as an opportunity for the U.S. and EU to work together to better advance export controls in multilateral regimes, as well as to develop common approaches to the implementation of multilateral controls, both in terms of timing and substance. To encourage the effectiveness of such regimes, ITI encourages the U.S. and EU to prioritize policy alignment and hold technical consultations prior to the proposal of and alongside the discussion and adoption of new controls within multilateral regimes. Several discrete issues could also benefit from robust U.S.-EU cooperation under the TTC, such as exporting the U.S. approach to intangible transfers, providing for U.S.-EU alignment on treatment of encrypted data, and pursuing mutual recognition of licensing approaches.

ITI’s submission highlights its ongoing engagement with the TTC, building on ITI’s representation of the global technology industry during the forum’s inaugural meeting in Pittsburgh in September 2021, and its recommendations in January 2021 and July 2021.

Read the full comments here.

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