USCBC Concerned Proposed US Export Control Rules Are Too Broad and Will Harm American Companies
Departing from the “small yard, high fence” framework could result in unintended commercial decoupling from China.
WASHINGTON—October 11, 2024—The US-China Business Council (USCBC), a private, nonpartisan, nonprofit trade organization of more than 270 American companies that do business in China, urged the Commerce Department to take a focused approach to its proposed end-use and end-user export controls in public comments filed today.
“While we support efforts to protect US national security, we are concerned that the proposed rules will unduly restrict trade in areas with little national security risk and unilaterally disadvantage American companies’ global competitiveness, including in public health,” USCBC President Craig Allen said. “The proposed rules should be much more focused in their scope to address clear and identifiable national security and foreign policy risks and not impede the vast amount of commerce that does not implicate these concerns and helps support American jobs and stabilize the global economy.”
If implemented as written, the proposed rules will amend and create four classes of end users for which an export license is required to transact with. Unless otherwise specified by the Bureau of Industry and Security, it would be incumbent on industry to determine whether a potential customer falls into one of the covered categories, representing a paradigm shift in the way companies are expected to act as an extension of the government in international trade.
USCBC recommends limiting the new rules to firms and products formally designated as having national security and foreign policy implications on the Entity List and the Commerce Control List. Additionally, USCBC is asking for clear and consistent definitions throughout the rules to ensure they do not have adverse impacts on non-sensitive sectors such as healthcare and consumer products.
Established in 1973, USCBC represents many of the world’s most iconic brands operating in China, and for more than 50 years has advocated on behalf of its members while promoting the many benefits of commercial exchange between the United States and China.
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美中贸易全国委员会（USCBC）是非政府、无党派、非营利的机构，自1973年成立以来，委员会为会员企业提供了大量的信息、咨询、倡导、活动等服务。通过设在华盛顿的总部以及北京和上海的办事处，美中贸易全国委员会以其独特的定位优势在中、美两地为我们的会员提供服务。
美中贸易全国委员会的使命是扩大中美商务联系，为在华的美资企业提供服务，帮助其发展在华业务。长期以来，美中贸易全国委员会接待了中美两国政府诸多高级官员，同时也在美国和中国多次成功举办会员企业与两国政要的会晤。获取更多信息，请浏览 www.uschina.org。
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