Comments on the U.S. Commerce Department’s Proposed “China Rule” (Authorizing Validated End Users)

U.S. Department of Commerce
Bureau of Industry and Security
Regulatory Policy Division
Room 2705
14th Street and Pennsylvania Avenue, NW
Washington, DC 20230

RE: Comments on Proposed Rule – Revisions and Clarification of Export and Reexport Controls for the People’s Republic of China (PRC); New Authorization Validated End-User

Dear Sir or Madam,

The Wisconsin Project on Nuclear Arms Control (“Project”) submits the following comments in response to the Commerce Department’s Bureau of Industry and Security’s (“BIS’s”) July 6, 2006, Proposed Rule (71 Fed. Reg. 38313) setting forth Revisions and Clarification of Export and Reexport Controls for the People’s Republic of China (PRC) and a New Authorization Validated End-User. The Project is a non-profit organization conducting outreach and public education to bolster the nonproliferation of mass destruction weapons and their means of delivery. For more than twenty years, the Project has pursued its mission by advocating for strong and effective export controls worldwide. The Project commends the Commerce Department for the step it has taken in the direction of controlling sensitive American exports to China by publishing this proposed rule. It is not in the interest of the United States to allow its products to help China build up its military strength. There are two separate initiatives introduced in the rule; they deserve to be considered individually. Unfortunately, both initiatives have serious problems which are discussed below. We recommend that the proposed rule be withdrawn for further consideration by the Department.

To read the complete letter, click here:  Comments on the U.S. Commerce Department’s Proposed “China Rule” (Authorizing Validated End Users)