Export Controls for Quantum, Semiconductors, 3D Printing

Summary#

The government published a proposed Order Amending the Export Control List on December 21, 2024. If adopted, it would add several advanced technologies—mainly linked to quantum computing, advanced semiconductors, metal 3D printing, and high‑temperature coatings—to the Export Control List, meaning exporters would generally need an export permit before sending them abroad.

What it does#

• Adds specific quantum‑related items to the list, including:
  • isotopically enriched silicon and germanium with impurity below 0.08%;
  • cryogenic cooling systems that meet tight performance thresholds (for example, systems with cooling power ≥ 600 µW at or below 0.1 K, or two‑stage pulse tube coolers maintaining ≤ 4 K with ≥ 1.5 W at 4.2 K);
  • cryogenic wafer probers that test wafers ≥ 100 mm at temperatures ≤ 4.5 K;
  • parametric (quantum‑limited) signal amplifiers operating below 1 K across 2 GHz to 15 GHz with noise figure < 0.015 dB.
• Controls certain advanced semiconductor production inputs:
  • masks, reticles and pellicles designed for EUV lithography used to make integrated circuits.
• Controls higher‑end metal additive manufacturing equipment:
  • metal 3D printers that use a laser, electron beam or electric arc; operate in an inert gas or vacuum (≤ 100 Pa); include in‑process monitoring (e.g., cameras, pyrometers); and have closed‑loop control systems.
• Controls high‑temperature coating technology:
  • coatings for ceramic matrix composite parts that operate above 1 100 °C.
• Keeps the usual exemption for exports to the United States (many ECL items still do not require a permit for the U.S.).
• This is a proposal (not yet law). The public comment period is 30 days after Part I publication, and the order would come into force 30 days after it appears in Part II if adopted.

Who's affected#

• Exporters and manufacturers in these fields: companies working on quantum computing, advanced semiconductors, metal additive manufacturing, and high‑temperature coatings.
• Researchers and universities that send controlled equipment, parts, or technical data abroad.
• Small businesses involved in these technologies (the government notes some affected firms are small).
• The permit issuer and enforcement bodies: Global Affairs Canada (permit reviews), Canada Border Services Agency, and the Royal Canadian Mounted Police (enforcement).
• The government expects the direct number of export transactions to be small (it estimates fewer than 100 permit applications per year and that fewer than 10 companies currently make or use these items). That estimate comes from the department and could change as technologies develop.

Why it matters#

• The change is meant to limit the export of technologies that can have both civilian and military uses, helping protect national and allied security and prevent sensitive tools from being used to upgrade weapons or break encrypted communications.
• For companies and researchers it means extra paperwork and permission steps for exports of the listed items (the government says typical processing is about 10 business days for low‑risk destinations and about 40 business days when wider consultation is required).
• The expected overall economic impact is described as small by officials, but the rule could affect research collaborations, international repairs or maintenance (sending parts abroad), and future business if the technology spreads.
• The technology moves quickly; the government notes uncertainty and says it will monitor developments and may adjust the controls over time.