EECARO has read with great interest the factsheet with proposed research security risk appraisal building blocks from the European Commission. Based on its members’ experiences linked to export control risk appraisal and the significant overlap in risk assessment between export control and research security, EECARO provides firstly some general observations and recommendations. Secondly, it mentions some specific comments per building block.
On the 24th of January 2024, the European Commission presented the White Paper on options for dual use research in the new multiannual framework programme, as part of the Economic Security Package. The White Paper states that the current funding instruments (Horizon Europe and the European Defence Fund, but also the European Investment Bank instruments) do not provide sufficient opportunities for synergies and cross-fertilization between civil and defence technologies in the European industry. EECARO welcomes the opportunity to comment on the White Paper. Download detailed comments here.
The White Paper on Export Controls, published on 24 January 2024 by the European Commission, outlines several response proposals to foster uniform and effective controls across the European Union (EU) and to open a discussion with EU Member States and stakeholders, including the research community, on the evaluation of the functioning of the Dual-Use Regulation and the ability of the current framework to effectively meet the EU’s present and future security needs. The European Export Control Association for Research Organisations (EECARO) welcomes the opportunity to provide feedback on the White Paper on Export Controls. Download detailed comments here.
EECARO welcomes the stakeholder consultation in preparation of the Commission proposal for a Council Recommendation on boosting research security in the European Union. EECARO focuses its initial feedback, grouped into the 8 points as in the attached file, to the intersection between export controls, research security, economic security and knowledge security. Download here.
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EECARO has responded on February 23, 2023 to the EU Consultation on Guidelines for data collection and preparation of the EU annual report on dual-use export controls under Regulation (EU) 821/2021. EECARO has proposed recommendations to enhance the public reporting and transparency as to contribute to a (much needed) level playing field within the European Union regarding the application of export licensing criteria, updates to the control list and the enforcement of common export control rules.
As per the considerations mentioned in recital (13) of the Regulation, the European introduction of a license requirement for ‘technical assistance’ is to increase the awareness, especially in research organisations and universities, of the risks associated with the provision of such ‘technical assistance’. To address these risks through an effective and robust compliance programme, EECARO calls out to the EU legislator to provide additional guidance on the interpretation of the specific conditional requirements in article 8 of the Regulation.
EECARO has addressed the importance of a common approach regarding the interpretation and application of export control laws and regulations in the US and EU and provided comments to the Working Group 7 of the EU-US Trade and Technology Council (TTC).