The 30-day consultation period running until January 20, 2025, concerns proposed amendments to Canada’s Export Control List (ECL) under the Export and Import Permits Act (EIPA). The initiative, sponsored by the Department of Foreign Affairs, Trade, and Development, aims to address the evolving risks posed by advanced technologies with potential military applications. These technologies include quantum computing, advanced semiconductor manufacturing, metal additive manufacturing machines, and high-temperature coating technology, which could significantly impact national and international security if misused. Countries like the United States, the United Kingdom, Germany, and Italy have already implemented export controls on such technologies, prompting Canada to take action to maintain alignment with its allies and improve global security measures.

The ECL is a regulatory framework controlling the export of specific goods and technologies from Canada. Amendments to the ECL often arise from Canada’s commitments to multilateral export control and non-proliferation regimes such as the Wassenaar Arrangement, the Nuclear Suppliers Group, the Missile Technology Control Regime, and the Australia Group. However, recent geopolitical shifts and the rapid advancement of militarily significant technologies necessitate a more proactive and adaptive regulatory approach. In May 2024, Canada and several allies introduced controls on five specific technologies, including quantum computing and advanced semiconductors, under Group 5 of the ECL, which covers items of strategic significance.

Quantum computing exemplifies the dual-use nature of emerging technologies, offering benefits for fields like medicine and simulation while posing risks to national security. A sufficiently advanced quantum computer could undermine public-key cryptography, threatening encrypted communication systems and software integrity. While quantum computers are already subject to export controls, associated components like cryogenic cooling systems, isotopically enriched materials, cryogenic wafer probers, and parametric signal amplifiers remain largely unregulated. These components are critical for the development and functionality of quantum computing systems and must be subjected to export permits to mitigate potential misuse.

Advanced semiconductor manufacturing also presents significant security implications. Semiconductors, vital to modern electronic and military systems, are becoming increasingly sophisticated through techniques like extreme ultraviolet (EUV) lithography. While the lithography systems themselves are regulated, essential components like masks, reticles, and pellicles used in their production are not. These unregulated items could enable the production of cutting-edge semiconductor devices with enhanced performance, potentially bolstering military systems or enabling the proliferation of advanced weaponry.

The proposed amendments aim to align Canada’s export control measures with those of its allies, safeguarding national and international security while fostering responsible technological development.

Canada (Proposed) December 21, 2024