JIIA Strategic Comments (2022-07)
Papers in the "JIIA Strategic Commentary Series" are prepared mainly by JIIA research fellows to provide commentary and policy-oriented analyses on significant international affairs issues in a readily comprehensible and timely manner.
Introduction
Immediately after the start of Russia's invasion of Ukraine on February 24, the US government announced that it, along with allies and partners, would implement broad economic sanctions and stringent export controls1. Export controls by the US and other governments on Russia and Belarus (hereinafter referred to as "the Export Controls on Russia") were implemented exceptionally promptly and on a historically large scale. International alignments for the Export Controls on Russia coordinate the design and implementation of export controls in individual countries and drive the direction of future export controls. Considering the above, this paper examines international alignments for the Export Controls on Russia and their implications.
Large Scale and Prompt Development
The Export Controls on Russia imposed by the US and other governments are of a scale and speed rarely seen in history. On February 24, the day Russia launched its invasion of Ukraine, the US government announced that unprecedented export control measures would cut off more than half of Russia's high-tech imports, restrict Russia's access to vital technological inputs, atrophy its industrial base, and undercut Russia's strategic ambitions to exert influence on the world stage2.
On the same day, the US Department of Commerce targeted Russia's defense, aerospace and maritime sectors, effectively banning exports of such items as semiconductors, computers, telecommunications devices, information security equipment, lasers and sensors to these sectors3. The US Department of Commerce's Bureau of Industry and Security (BIS) has stated that the BIS's aim is to restrict Russia's access to items that can support the country's defense industrial bases, military and intelligence services. "With these export controls, we, together with our allies and partners, are technologically isolating Russia and degrading its military capabilities," said Assistant Secretary of Commerce for Industry and Security Thea D. Rozman Kendler. In addition, the Foreign Direct Product (FDP) rules for export control to Russia were strengthened, and 49 Russian military end-user entities were added to the Entity List (EL), making them subject to strict export control. The bolstering of the FDP rules requires the approval of the US Department of Commerce when exporting to Russia items that directly incorporate certain US-made technologies and software, or when exporting items that incorporate US-made technologies and software to the Russian entities listed on the EL4. These rule enhancements are based on the measures implemented by the US government in 2020 to control exports to Huawei, but Japan and other countries that jointly coordinating with the US on the Export Controls on Russia are exempt from these FDP rules. The US Department of Commerce has subsequently strengthened the Export Controls on Russia by gradually adding more than 200 entities to the EL, adding luxury goods to controlled items, and subjecting all items on its Commercial Control List (CCL) to export controls5. The scope of sanctions imposed on Russia by the US government's export controls has become extensive.
The governments of Japan and countries in Europe and elsewhere are implementing large-scale the Export Controls on Russia together with the US government. For example, the Japanese government has repeatedly and promptly implemented large-scale export control measures in line with the governments of these countries. On February 23, the Japanese government had announced import and export restrictions on "the Donetsk People's Republic" and "the Luhansk People's Republic" (both self-proclaimed), and following Russia's invasion of Ukraine, Prime Minister Kishida announced on the 24th that Japan would work together with the G7 and other members of the international community6.Following this, on the 25th, the Ministry of Economy, Trade and Industry (METI) restricted exports to Russia of items listed under the multilateral export control regimes, general-purpose goods such as integrated circuits thought to help enhance Russia's military capabilities, and items related to petroleum refining. Furthermore, on March 16, a restriction on exports of luxury goods to Russia was announced (and enforced from April 5). The Japanese government also restricts exports to certain entities related to Russia. By March 25, the Japanese government had designated 130 entities subject to the Export Controls on Russia, marking the first time that Japan has attempted to designate specific entities subject to export controls. The Japanese government's export controls to date have focused on end-use. In this way, the governments of Japan and the US have kept in step regarding the Export Controls on Russia.
The same can be said of the European Union (EU). The EU is also deploying the Export Controls on Russia in tandem with the US and other countries. In this regard, Denis Redonnet, Deputy Director General for Trade and Chief Trade Enforcement Officer (CTEO) of the European Commission, said, "As a result of the implementation of the sanctions package we have created a sort of autonomous regime of export controls at EU level not just on export control of dual-use items but also on a range of emerging technologies and advanced technologies." He also stressed the speed with which the EU had worked out a new export control framework for Russia in a matter of weeks7. The EU, in tandem with the United States and other countries, has responded promptly and extensively.
In this way, the governments of Japan, the United States, Europe, and other countries cooperated on the Export Controls on Russia and deepened their cooperation in designing their measures and sharing information. When the US Commerce Department launched the Export Controls on Russia on February 24, it revealed that the measures reflected important cooperation among the US, EU, Japan, Australia, UK, Canada, and New Zealand8. At this point, thirty-three countries were already in step with each other in the Export Controls on Russia - the Five Eyes countries, the 27 member countries of the EU, and Japan - and international alignment for the Export Control had begun beyond the G7.
Subsequently, the number of countries that joined in the international cooperation on the Export Controls on Russia increased. Although the South Korean government did not implement sanctions against Russia when Russia annexed Crimea in 2014, President Moon Jae-in announced on February 24, 2022 his intention to go along with the sanctions against Russia9. On the 28th the South Korean government decided to restrict exports to Russia of listed items under the multilateral export control regimes and announced that it would start considering semiconductors and other items that the US had designated as controlled items10. Furthermore, on April 8, the US government announced that Switzerland, Norway, Iceland and Liechtenstein would be taking new steps in cooperation with the Export Controls on Russia11. Exceptions to the US FDP rules apply to these thirty-seven countries that are in tandem with the US.
As of this writing, then, thirty-eight countries are in step with the Export Controls on Russia. In just a month and a half, a de facto international export control framework was formed beyond the G7. In terms of the number of participating countries, more countries have already joined this framework than the thirty-five countries that are members of the Missile Technology Control Regime (MTCR). The US government refers to this framework as the "Global Export Controls Coalition"12, and T.D.R. Kendler said that the governments participating in the Global Export Controls Coalition are coordinating export licensing policies and sharing information13.
Effectiveness of the Export Controls on Russia
When considering the effectiveness of international export controls, it is necessary to examine two aspects. One is the problem-solving aspect. In general, the effectiveness of an international institution is evaluated by the degree to which it has succeeded in solving the problems that led to its establishment14. Given that on February 24, the US Department of Commerce announced it would impose strict export controls severely restricting Russia's access to technologies and other items needed to sustain its aggressive military capabilities15, a criterion of effectiveness would be the extent to which these export controls undermine Russia's military capability base, the objective of the Export Controls on Russia.
In this regard, the US government and the EU seem confident that the Export Controls on Russia have been effective to some extent. According to Commerce Secretary Gina Raimondo, Russia's high-tech imports have been cut by more than half due to export controls implemented by the US and its allies. Russia is facing difficulties in finding parts for tanks, satellites and rocket-launching systems due to export controls, and is also short of semiconductors for night-vision goggles and avionics16. On March 30, Ms. Kendler stated that "Unlike financial sanctions, our export control measures were never expected to have immediate effects" but "as compared to the same time period last year, US exports to Russia of items subject to new licensing requirements have decreased by 99% by value. 17" She then noted a report by the Ukrainian government that Russia's two major tank plants had halted work due to lack of foreign components and that Baikal Electronics, a Russian fabless semiconductor company, had been cut off from the integrated circuits needed to support its domestic communications equipment - including surveillance, industrial controls, servers, and more18. Matthew Borman, Deputy Assistant Secretary of Commerce for Export Administration, also said "Russian manufacturing facilities - including those that are involved in manufacturing military vehicles - have had to shut down production because they are not able to get the components, particularly semiconductors, that they need for their products," and "in terms of the impact, I think you've already seen some, and continuing." Mr. Borman also indicated that the reason for the effectiveness of the Export Controls on Russia was due to cooperation with allies and partners as well as self-regulation by private companies19.
In addition, the EU seems to be seeing some effects from the Export Controls on Russia. European Commission CTEO Redonnet pointed out that, based on customs data, EU exports to Russia had fallen by about 70% compared to before Russia's invasion of Ukraine20.
Furthermore, as Deputy Assistant Secretary Bowman pointed out, the effectiveness of export controls on Russia has been enhanced by self-regulation undertaken by multinational companies21. In the semiconductor industry, for example, vertically integrated chip maker Intel said it suspended all exports to Russia and Belarus in March and all operations in Russia in April22. In the field of integrated circuit design, Advanced Micro Devices (AMD) and Nvidia have also reportedly halted exports to Russia23. The cloud industry is also seeing some self-regulation by private companies. In March, Microsoft, Amazon and Google, which had established dominant positions in Russia's domestic cloud market, announced that they had stopped offering their cloud services in Russia24. The actions taken by these semiconductor and cloud companies will have serious medium- to long-term consequences for Russian companies and government agencies that rely heavily on foreign semiconductor designs and foreign cloud services.
When considering the effectiveness of cooperation in international export controls, the implementation and administration of export controls by members are also taken into account. In this case, the question is whether export controls are implemented stringently or with laxity25. As for the Export Controls on Russia, backfilling issues that compensate for these measures have proven challenging, and there are certainly some who question the effectiveness of the Export Controls on Russia in this sense. For example, Nazak Nikakhtar, former Assistant Secretary of State for Industry Analysis at the US Department of Commerce's International Trade Administration (ITA), has raised doubts about the possibility of the US Department of Commerce conducting end-use checks in Russia, saying that the effectiveness of export controls on Russia depends on whether exports to Russia comply with export control rules. She has also pointed out that the lack of identification of violations may not be due to the absence of violations, but rather to the failure to track violations. In particular, she took a negative view of China's compliance with international export controls toward Russia26. Of course, we cannot rule out the possibility (especially if sanctions are imposed for a long period of time) that some enterprises will seek opportunities to start or continue business with Russia by circumventing the Export Controls on Russia by the US government and others. US Deputy Assistant Secretary of Commerce Borman, however, said on March 29 that no compliance issues had been found in Asia and that Russia would not be able to find workarounds in trying to procure chips from European countries, Japan, and South Korea27. Regarding the Commerce Department's end-use checks in Russia, it was also reported that some Commerce Department officials believe they are still working28.
In fact, as of this writing, no clear backfilling has been found that would compensate for the Export Controls on Russia by the governments concerned. For example, the Global Times, an English-language Chinese newspaper under the People's Daily, the official newspaper of the Chinese Communist Party, reported that Chinese companies are hesitant to supply semiconductors to Russia, even though the country is increasingly seeking semiconductors. The cautious stance of Chinese companies reportedly stems from the threat of US sanctions to payments29. Some in the Commerce Department think Chinese companies that want to secure access to US technologies are complying with US regulations30. Also suggestive, although not directly related to export controls, are reports that Chinese banks have restricted purchases of Russian items and loans to Russia. This suggests that Chinese companies are complying with US sanctions in order not to be designated targets of US sanctions31. In addition, some Chinese companies that continue to do business with Russian companies were reportedly stopped from doing business by European companies32. It is undeniable that the decision of European companies to stop doing business with Russian companies will affect the decision of Chinese companies. Considering these circumstances, it is conceivable that Chinese companies may compare the Western and the Russian markets and choose the Western market over the Russian one33. Even if the Chinese government were to take concrete measures against the US-led Export Controls on Russia, Chinese companies would not necessarily be in step with the authorities.
This situation suggests that the "Global Export Controls Coalition," as the US government calls it, may be functioning as a de facto international export control system. The US Commerce Department has described the Global Export Controls Coalition as a "global coalition of nations that are cooperating in our stand against Russian aggression, and Belarusian complicity, through their implementation of similarly stringent export controls34." At the time of this writing, thirty-eight countries are said to be members of the Global Export Controls Coalition, and it is believed that the Export Controls on Russia are in fact being administered and implemented beyond the membership of the Global Export Controls Coalition. Thus, the effectiveness of export controls by the Global Export Controls Coalition has been maintained, in terms of both constraints on Russia's military capabilities and administration and implementation of export controls.
International Alignment for the Export Controls on Russia
The rapid deployment of the large-scale and effective Export Controls on Russia was due to the successful coordination of export controls by various governments. According to US Assistant Secretary of Commerce Kendler, governments had extensive international dialogue on the design, coordination, and execution of export control measures. Kendler said that the day-to-day work and engagement between the Commerce Department's BIS and its counterparts have been effective and that the US is closer to its allies than it has been in decades in terms of export controls. She said, "my Treasury colleagues and I traveled to London, Brussels, Paris and Berlin to bring this coalition together" and "[while] we were not able to travel to other destinations, thanks to the use of technology, we held extensive dialogues with Japan, South Korea, Canada, Australia, and New Zealand, as well35."
In particular, the US-EU Trade Technology Council (TTC) played significant roles in the coordination between the US and EU on the Export Controls on Russia. The US-EU TTC was launched in June 2021 by the US government and the EU, and its inaugural meeting was held in Pittsburgh in September. It is a platform for cooperation between the US and the EU in areas such as technology, digital issues, and supply chains. At this first meeting, the US-EU TTC stated that the objectives were "to coordinate approaches to key global technology, economic, and trade issues, and to deepen transatlantic trade and economic relations, basing policies on shared democratic values36." The US-EU TTC has 10 working groups that focus on technical standards, investment screening, export controls, and so on. Working Group 7 on export controls was initially tasked to engage in technical consultations on legislative and regulatory developments and exchange information on risk assessments and licensing good practices, as well as on compliance and enforcement approaches, promote convergent control approaches on sensitive dual-use technologies, and perform joint industry outreach on dual-use export controls37.
It is said that the US-EU TTC played greater roles than originally expected in controlling exports to Russia. According to Assistant Commerce Secretary Kendler, the US EU-TTC was launched with two objectives: "to coordinate approaches to key global technology, economic, and trade issues; and to deepen transatlantic trade and economic relations based on shared democratic values." However, "[t]his crisis has brought partner countries' export controls authorities closer than ever38." Kendler visited European countries as mentioned above, and "Deputy Assistant Secretary for Export Administration Matt Borman spent the following week in Brussels building on our work and bringing us to final common ground," she revealed39.
The EU has also expressed its view that the US-EU TTC has played more important roles than initially expected in US-European cooperation on the Export Controls on Russia. European Commission CTEO Redonnet said he believed the situation in Russia and Ukraine had greatly accelerated EU-US cooperation. Referring to the US-EU TTC after Russia invaded Ukraine, he stated, "[f]rankly, we have leapfrogged compared to what we were planning to do less than six months ago40." The US-EU TTC has become a tool for cooperation that the US and EU did not previously have. European Commission Executive Vice-President Valdis Dombrovskis, speaking at the European Parliament on the US-EU TTC, said good progress had been made "on work on export controls, specifically towards Russia," and added "[i]n response to the Russian invasion of Ukraine, the TTC has already facilitated alignment with the US on export restrictions for dual-use items and technologies to Russia and Belarus." He declared, "I believe that the coordinated transatlantic response to Russia's aggression would not have been as fast and smooth without the trust and good cooperation already built by the TTC," and then attributed the basic posture of coordination between the US and EU on the Export Controls on Russia to the US-EU TTC41. Stavros Lambrinidis, the EU's ambassador to the United States, was more specific in this regard, saying, "every player that is important in this field could simply pick up the phone, have the conversation and make it, done." He revealed that dialogue and coordination based on the US-EU TTC had contributed to the prompt implementation of export controls on Russia. According to him, sanctions were carefully coordinated from the political to the technical level. One example was that, when the EU banned Airbus from exporting planes and spare parts to Russia, the US government imposed similar measures on Boeing42. Mr. Redonnet also said that, when considering sanctions against Russia, the European Commission ran several simulations, including the impact of a full embargo, and considered Russia's dependence on G7 countries when identifying the items to be subject to export controls43. It is not hard to imagine that the results of these analyses were shared between the US and Europe to design actual export control measures. It seems that the US-EU TTC played a key role in the rapid and smooth implementation of this unprecedented large-scale export control cooperation across the Atlantic. Unlike the case of strengthening export controls on Huawei in 2020, which brought about the extraterritorial application of export control measures by the US government, the US-EU TTC enabled the US and Europe to cooperate in export controls on Russia. This was also important to avoid unnecessary tensions between the US and the EU, Redonnet said44.
On the other hand, the Indo-Pacific region does not have a sufficient institutional framework to coordinate the Export Controls on Russia. To be sure, Japan and the US have a framework to support export control coordination. On April 8, 2022, a sub-ministerial-level meeting of the Japan-US Commercial and Industrial Partnership (JUCIP) was held at which export controls, as well as semiconductors and the digital economy, were discussed45. In November 2021, Minister of Economy, Trade and Industry Koichi Hagiuda and US Secretary of Commerce Raimondo agreed to establish JUCIP with the aim of promoting cooperation with like-minded countries, including those in the Indo-Pacific region, on strengthening the industrial competitiveness of Japan and the US and on strengthening supply chains46. In addition, Japan, the US and Europe have held trilateral meetings of trade ministers that provide a basis for promoting international cooperation. However, they have not extended this framework of Japan, the US and Europe to include countries from the Indo-Pacific region. It is also unclear whether these forums have working groups or other bodies dedicated to export control. The absence of an institutionalized platform for coordinating export controls among Japan, the US, Australia, New Zealand, Canada and South Korea may be the reason it is difficult for the region to demonstrate strong leadership in international export control cooperation or to launch its own initiatives.
Conclusion
As described above, in the wake of Russia's invasion of Ukraine, Japan, the US, European countries, Australia and other governments have implemented the large-scale Export Controls on Russia. The effective and prompt deployment of the Export Controls on Russia was underpinned by the coordination of export controls among multiple governments. US Deputy Assistant Secretary of Commerce Borman expressed his gratitude for the partnership with governments and companies in the Asia-Pacific region and stated that he hoped to continue to expand the "coalition" imposing the Export Controls on Russia47. It can be seen there that he is looking at the export control framework in the context of relations with China. "As much as the Russia crisis has occupied us these last couple of months, we have not diverted from our other national security priorities, and the modernization of China's military is the national security priority for us," Kendler said48. Below I would like to explore the issues and implications for the Asia-Pacific region rather than simply summarizing this paper.
The first issue concerns Taiwan and Singapore. In the wake of Russia's invasion of Ukraine, Taiwan and Singapore have taken a stance to align themselves to the export controls by the US and other countries. On February 25, Su Tseng-chang, the premier of Taiwan, announced that the Taiwanese authorities would be joining in the economic sanctions against Russia49. Taiwan Semiconductor Manufacturing Company Limited (TSMC), the largest semiconductor manufacturing company in the world, announced its intention to comply with the Export Controls on Russia50. "TSMC's exit from the Russia market has cut off the Moscow Center of SPARC Technologies' access to Elbrus chips, which are widely used in Russian intelligence and military systems," Kendler said51. TSMC also builds the latest Baikal microprocessor, widely used in many Russian-made computers and servers52. It is significant that Taiwan and TSMC are in tandem with the Export Controls on Russia.
The Singapore government in early March also announced details of sanctions against Russia for its aggression in Ukraine. These measures included a ban on the export and re-export of electronics and other products to Russia53. Although Singapore, a transit point for international trade, is not a member of the existing multilateral export control regimes (Australia Group [AG], Missile Technology Control Regime [MTCR], Nuclear Suppliers Group [NSG], Wassenaar Arrangement [WA]), it is an important country for multilateral export control because it places the items covered by these regimes on its export control list. It is important for enhancing the effectiveness of export controls to include Taiwan (and TSMC), which dominates the pre-processes in the semiconductor value chain, and Singapore, which is a logistics hub. However, when the US government referred to "the Global Export Controls Coalition," it did not mention Taiwan or Singapore as members. Washington has also not explicitly said that it would treat Taiwan and Singapore as exempt from the FDP rules. Dealing with Taiwan and Singapore within the framework of international export controls will be a critical issue.
The second is the treatment of India. As is well known, the Indian government has taken a passive stance toward sanctions against Russia, including its abstention on the February 25 UN Security Council resolution, and has shown no signs of supporting the Export Controls on Russia by Japan, the United States and Europe. Therefore, European Commission CTEO Redonnet was cautious about the possibility of extending cooperation at the US-EU TTC beyond the transatlantic effort. It is not easy to get countries such as India and China to join hands, he said54. The Indian government's stance on sanctions against Russia, including export controls, may have an impact on India's economic security policy. In some cases, this could cast a dark shadow over the path of foreign support for India's semiconductor industry. There is a possibility that Japan, the US, Europe, Taiwan and others may be reluctant to support the development of the Indian semiconductor industry by judging that the development of the Indian semiconductor industry will eventually contribute to the maintenance and enhancement of Russia's military capabilities. India, a member of the Quad consisting of Japan, the US, Australia and India, will have to make a difficult decision between continuing cooperation with Russia and fostering domestic semiconductors.
However, there are signs that India is gradually reducing its dependence on Russia. For example, some in the US believe that India will ultimately choose the US over Russia. Derek Chollet, Counselor of the US Department of State, said he did not expect Russia to be a reliable partner for India for the foreseeable future because "[with regard to] the export control against Russia... Russia's inability to import key technologies to be able to make certain products, including some of its military hardware, are going to mean that it's going to have a hard time even getting the capability to replace or to produce this kind of material. So, any way you look at it in terms of actual capability, in terms of the difficulty of doing business with Russia, in terms of the reputation costs associated, Russia is just a far less attractive partner55." The India-EU TTC, agreed on April 25 by European Commission President Ursula von der Leyen and Indian Prime Minister Narendra Modi, could be a touchstone for India's future economic security policy. According to a press release, "[t]his strategic coordination mechanism will allow both partners to tackle challenges at the nexus of trade, trusted technology and security, and thus deepen cooperation in these fields between the EU and India," and "[e]stablishing the EU-India Trade and Technology Council is a key step towards a strengthened strategic partnership for the benefit of all peoples in the EU and India56." Certainly, it is unclear whether the India-EU TTC will contribute to the coordination of export control policies at a level comparable to that of the US-EU TTC. However, the India-EU TTC could be seen as an attempt to institutionalize cooperation between India and the EU in the areas of trade, technology and security, and to reduce India's relative dependence on Russia.
The third concerns plurilateral measures. In this case, plurilateral measures are measures based on a framework of countries sharing common interests and values. In June 2021, the Japanese government announced that it would "[a]im for the early realization of a new security trade control framework that complements the existing international export control regimes57." In March 2022, the US Department of Commerce announced in its strategic plan for fiscal 2022-26 that it would "expand plurilateral and bilateral cooperation with allies and like-minded countries specific to export control policy and information sharing58." As mentioned earlier, several plurilateral frameworks served to enhance international cooperation on the Export Controls on Russia. The first is what the US calls "the Global Export Controls Coalition." Initially, thirty-three countries - the Five Eyes countries, 27 EU countries, and Japan - were members of the Coalition. Since then, countries such as South Korea and Switzerland have joined and, as of this writing, thirty-eight countries have joined the Global Export Controls Coalition. The US-EU TTC also made a significant contribution to the coordination of export controls across the Atlantic.
Such plurilateral frameworks for the Export Controls on Russia may develop into a framework that goes beyond export controls toward Russia and Belarus. In this case, the list of controlled items, the list of controlled entities, the adjustment of licensing policies, and the exchange of information will be conducted based on the experience of the Export Controls on Russia. The know-how and experience gained by the US-EU TTC during this crisis may be appropriated, and the number of participating members may increase or decrease. Nazak Nikakhtar, a former US Commerce Department official, said the success of international cooperation in such areas as export controls on Russia could serve as a model for future export controls on China59. In this regard, Assistant Secretary Kendler said "we share a purpose beyond that of responding to Putin's war" and "[we] are looking to build on the relationships that have developed in the last weeks60." In fact, there seems to be a movement to further develop export controls in the US-EU TTC, which was advanced in response to the Ukraine crisis. Speaking in the European Parliament on March 22, European Commission Executive Vice-President Dombrovskis said: "On export controls, we continue to push in Working Group 7 for more coherence in our policies, and for information exchanges, including on critical technologies61." Commerce Secretary Raimondo also highlighted the US-EU TTC Working Group on Export Control Cooperation when he met with European Commission Executive Vice-President Charles Dombrovskis on April 2162.
There are also those who expect the Biden administration's "Indo-Pacific Economic Framework (IPEF)" to play a role. Although the details remain unclear as of this writing, IPEF is an Asia-Pacific trade and economic initiative announced by President Biden in October 2021. For example, Yeo Han-koo, South Korea's Minister for Trade, proposed that the US-EU TTC be used as a reference point for export control cooperation by IPEF members63. The argument is that the IPEF should deal with export controls based on the model of the US-EU TTC. There are US companies as well advocating that the IPEF deal with export controls. For example, Intel pointed out that export controls in the IPEF would ensure the protection of international security and support for a level playing field globally, and noted that "[t]he IPEF presents an opportunity for the countries to work together to coordinate export control policy" in public comments to the US Department of Commerce64. In addition, the Semiconductor Industry Association (SIA), the Semiconductor Equipment and Materials International (SEMI), the Information Technology and Innovation Foundation (ITIF), and other organizations have also made recommendations to the US Department of Commerce regarding issues and points to consider in handling export controls in IPEF65. The key to these discussions was that the IPEF's handling of export controls would enable the implementation of export controls in a multifaceted manner, which would be expected to have a security effect and avoid unilateral US regulation. This reflects US industry's desire to avoid being put at a disadvantage in the international business arena.
Considering the above, multiple export control platforms could be developed that would give rise to an institutional complex of export controls. In addition to the Global Export Controls Coalition, the US-EU TTC, the India-EU TTC, and the IPEF, the "Export Controls and Human Rights Initiative" announced last December also merits attention. These plurilateral measures could have their own respective purposes. Governments may find themselves forum-shopping across multiple export control platforms. The relationship with existing multilateral export control regimes (NSG, AG, MTCR, WA) may also be questioned.
At this point, it is difficult to say with any confidence what form the international cooperation on export control will take in the future. However, there is no doubt that the large-scale Export Controls on Russia that were promptly developed in response to Russia's invasion of Ukraine had a significant impact on the international alignment of export controls, which in turn will affect not only international and national security but also the state of the international economy, including the restructuring of supply chains. Therefore, it is necessary to pay attention to the development of various frameworks for international alignment in export control.
(This is an English translation of the original Japanese version published on April 27, 2022)
* After this original Japanese version was published, the 2nd meeting of the US-EU TTC was held in Paris on May 16 and IPEF was launched in Tokyo on May 24.