Export controls on semiconductor devices, manufacturing equipment, materials, software and related technologies should be narrowly tailored to specific national security concerns and applied multilaterally to minimize global market distortions. Unilateral U.S. export restrictions in the face of foreign availability of interchangeable goods from non-U.S. sources harm companies with operations in the United States, without effectively restricting such items to end users of concern. Moreover, proposed changes to export control regulations should strive to provide industry stakeholders the opportunity to provide comments before they take effect.
Recent regulations to significantly expand the scope of items subject to the EAR and expand unilateral controls over most semiconductor equipment and design software, as well as some semiconductor devices, materials and technology, have the potential to result in significant negative impacts to the semiconductor industry and the broader technology sector that relies on predictable access to semiconductors.
Recent U.S. Export Control Position Letters
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