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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).