Updated DIGITALEUROPE Comments on Proposal for Recast of Export Control Regulation

DIGITALEUROPE, the industry association representing the digital technology industry in Europe, fully endorses the objectives of the European Commission to safeguard and promote human rights. Furthermore, DIGITALEUROPE fully supports the European Commission’s proposal to reform the export control regime in order to address the latest technological and political developments. DIGITALEUROPE recollects that the EU currently has a well-functioning export control system, implementing the results from the international export control regimes, also used by many third countries as a model and best practice. This system has been tested in practice for a long time and provides a solid legal baseline for exporters and Member States.

DIGITALEUROPE acknowledges the efforts of the European Parliament (hereafter: EP) to advance the Commission’s proposal for a modernization of the EU Export Control Regime. Following the plenary vote of the EP on 17 January 2018, we encourage the EP and Council to stand ready to work towards a legally sound and operational export control regime in line with the international best practices and export control regimes.

On the basis of the efforts of the EP, and in light of the ongoing discussions in the Council of the European Union, we deem it necessary to continue working on the proposed text. It is important that the principles and goals of the export control regime as well as legitimate business and societal interests can benefit from the reform in practice and any unintended consequences are prevented. Consequently, this paper sets out our suggestions for changes to the proposed Regulation following the vote in EP plenary on 17 January 2018.