ReMA Opposes Export Controls in Comments with the Bureau of Industry Security

Over the past 10 years, ReMA has successfully fought legislative efforts in Congress to impose export controls on certain used electronic products. Now the U.S. Department of Commerce Bureau of Industry Security is determining whether or not it will take further action to restrict exports and has requested comments from the industry.

In this notice for comment, the Bureau is suggesting restricting used non-working electronic products such as personal computers, cellphones, tablets, and other electronics to prevent counterfeit chips from getting into the supply chains of new electronics while referencing an earlier discovery of counterfeit components in sensitive military systems such as radars, fighter aircraft, and communications equipment.

As a result of that discovery, Congress passed legislation requiring the Department of Defense to establish trusted supply chains and institute a robust testing protocol. ReMA agreed with Congress’ approach since electronics are manufactured in many other nations and used throughout the world making restricting the exports from the United States meaningless. Moreover, restricting non-working electronics makes less practical sense than restricting working electronics. The U.S. electronics recycling industry regularly refurbishes electronics for overseas markets. However, many used electronics do not full functionality but still have markets in many developing nations where the cost of new electronics is prohibitive. By exporting these non-functioning devices, consumers elsewhere are able to extend the lifecycles of these products.

In addition to ISRI, the Bureau’s request for comments elicited comments from a variety of industries including the original equipment manufacturers, equipment leasing associations, the U.S. Chamber of Commerce and other industry groups. Additionally, ReMA and others have visited the Bureau to discuss this proposal and argue that it not go forward. 

The comments submitted by ReMA are available online.


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