New Export Controls for Emerging Technologies

Summary#

A proposed Order Amending the Export Control List was published in the Canada Gazette, Part I on December 21, 2024. It would add several advanced technologies — mostly linked to quantum computing, advanced semiconductors, metal additive manufacturing, and high temperature coatings — to the Export Control List, meaning exporters of those items would need an export permit under the Export and Import Permits Act. The proposal is open for comment for 30 days.

What it does#

• Adds specific quantum-related items to the Export Control List, such as:
  • isotopically enriched silicon and germanium with impurity below 0.08%;
  • cryogenic cooling systems that reach ultra-low temperatures (examples include systems that provide 600 µW at 0.1 K or two-stage pulse tube coolers that maintain 4 K and provide 1.5 W at that temperature);
  • parametric (quantum‑limited) amplifiers that operate below 1 K between 2 GHz and 15 GHz with noise figures under 0.015 dB;
  • cryogenic wafer probers that test wafers ≥ 100 mm at ≤ 4.5 K.
• Adds controls on advanced semiconductor production inputs:
  • EUV lithography masks, reticles and pellicles used for integrated circuits.
• Adds controls on metal 3D printing equipment:
  • metal additive manufacturing machines with features such as a laser/electron beam/electric arc source, a controlled inert or vacuum atmosphere (pressure ≤ 100 Pa), in‑process monitoring sensors (e.g., cameras, pyrometers) and closed‑loop control.
• Adds controls on coating technologies:
  • coating systems designed to protect ceramic matrix composites at temperatures above 1,100 °C.
• Once in force, exporters would generally need a permit to send these items out of Canada, but exports to the United States would generally remain exempt as is already common for many ECL items.
• The order is proposed now; if finalized it would come into force 30 days after publication in the Canada Gazette, Part II.

Who's affected#

• Companies and researchers working in:
  • quantum computing hardware and components;
  • advanced semiconductor manufacturing and EUV tool supply chains;
  • metal additive manufacturing (metal 3D printing) makers and users;
  • high temperature coatings for turbine or missile parts.
• Academia and individual researchers who export controlled technical data or hardware.
• Small businesses in these fields (the government expects some small-business impacts).
• Government bodies involved in enforcement and permitting, including Global Affairs Canada, the Canada Border Services Agency, and the Royal Canadian Mounted Police.
• The government estimates fewer than 100 permit applications per year related to these additions, and only a small number of companies (fewer than 10) currently make or use many of these specific technologies in Canada.

Why it matters#

• The changes aim to reduce the risk that cutting‑edge technologies are diverted for military uses or to harm national security. For example:
  • powerful quantum computers could weaken modern encryption;
  • advanced semiconductors and metal additive manufacturing can improve military systems or enable on‑site repair of equipment.
• Requiring export permits creates a review step that lets Canada vet end users and destinations. That can add short delays: complete applications are typically reviewed in 10 business days for low‑risk destinations and up to 40 business days for cases needing more consultation.
• The amendments also align Canada with allies (such as the United States, United Kingdom, Germany, and Italy) so Canada is less likely to be used as a transit point around other countries’ export controls.
• Practical takeaway: if you work with any of these specific technologies, you may soon need an export permit to send them or related technical information outside Canada.