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Coordinating Committee for Multilateral Export Controls

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The Coordinating Committee for Multilateral Export Controls (CoCom) was established in 1949[1] at the beginning of the Cold War to coordinate controls on exports from Western Bloc countries to the Soviet Union and its allies. Operating through informal consensus, CoCom maintained extensive control lists covering arms, nuclear materials, and dual-use technologies. However, CoCom faced criticism for weak enforcement and inconsistent application among member states. CoCom ceased to function on March 31, 1994, but its control list of embargoed goods remained in effect among member nations until the establishment of the Wassenaar Arrangement in 1996. CoCom's legacy continues to influence contemporary export control regimes, highlighting its enduring relevance in nonproliferation and technology policy.

Origins and Historical Context

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CoCom originated from the tense geopolitical atmosphere following World War II, as Western nations grew increasingly wary of advanced technology potentially reaching the Soviet Bloc. This concern spurred efforts to collaborate on limiting technology transfers to communist states.[2][3] Many of these concerns stemmed from America’s substantial technological investment in Japan during the 1930s, which helped Japan build East Asian industrial power ahead of WWII,[4] along with American containment doctrine. In response to the Soviet Union’s first nuclear test in 1949, the United States, United Kingdom, and France pursued confidential discussions to lay the groundwork for coordinated communist bloc export embargoes.[5][3] These discussions resulted in a covert “gentlemen’s agreement” establishing CoCom in late 1949, with operations beginning in early 1950.[2] CoCom was never formalized by treaty and operated informally, relying on unanimous consent for decisions, which limited its enforceability.[5] Consequently, the U.S. enacted the Battle Act in 1951 to encourage participation, threatening to cut aid to allies that traded with communist nations.[4] This attempt to steer the agenda fell short, as the relative warming of diplomatic relations through detente, coupled with the rapidly expanding economies of Europe and Japan becoming more intertwined with Eastern Europe, increased pressure on the United States to ease CoCom restrictions during the 1960s and 70s.[5]

In the 1980s, renewed concerns about Soviet technological gains and competitive pressures in global markets revived interest in CoCom. With the United States facing more global technological development competition, European nations questioned the strict export restrictions and often lax enforcement, criticizing the U.S.-driven trade limitations as inconsistent and politically motivated.[2] These concerns reinvigorated discussions of CoCom as a vital tool for controlling technology access to the Soviets and their allies, prompting meetings throughout the 1980s that reaffirmed member commitments to the CoCom. Nearly all countries in NATO joined CoCom by the late 1980s, and CoCom expanded its operations to add military advisors to advise on certain technologies and tighten licensing and enforcement measures. These initiatives laid the foundation for enhancing the reliability and effectiveness of the CoCom organization.[4]

Membership

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In its final years, CoCom had 17 member states:

Despite being neutral, Switzerland joined the CoCom sanctions against the Eastern bloc countries; see Hotz-Linder-Agreement [de].[6]

Laws and regulations

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In the United States, CoCom compliance was implemented via multiple statutes authorizing presidential export controls, including the Export Control Act of 1949, the Export Administration Act of 1969, the Export Administration Act of 1979, the Arms Export Control Act (AECA), the Trading with the Enemy Act, and the International Emergency Economic Powers Act, among others. Many of these statutes encouraged the coordination of controls with allies.[7] However, U.S. policies frequently exceeded CoCom’s collective controls, reinforcing American leadership but also creating friction with allies.[8] The Department of State and the Department of Commerce administered these coordinated controls via the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

Effectiveness and Impact

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CoCom’s export control lists were elaborate, specific, and systematically organized. CoCom had three categories of export controls: the Nuclear List—spanning uranium enrichment systems and nuclear reactor components; the International Munitions List—including guided missiles, advanced avionics, and other strategic military systems; and the Industrial List—containing dual-use items such as supercomputers and semiconductors.[9] Moreover, the export control lists were successfully updated in 1954, 1958, 1961, 1964, 1967, 1971, and 1974-1975 to reflect evolving geopolitical dynamics between CoCom constituents and the USSR.[10] President George H.W. Bush’s successful proposal to eliminate a significant number of industrial and dual-use CoCom export controls following the fall of the Berlin Wall and diminishing Soviet influence in Eastern Europe reflects CoCom’s adaptability.[9]Moreover, in 1992, CoCom members collectively agreed to expand membership to the former USSR.[11] The longevity of CoCom—lasting 30 years despite military risks that threatened its abolition—is also notable.[10]

Yet enforcement was weak and export control lists were often ambiguous. With only 14 staff in the 1980s, CoCom lacked robust inspection or sanction mechanisms. Disagreements over what constituted “dual-use” technology created ambiguity, causing poor export control enforcement.[10] Second, CoCom not only lacked large fines for violators but was also unable to impose sanctions against them.[10] Third, there were frequent complaints about American hypocrisy within CoCom—using export control mechanisms to delay competitors’ deals while greenlighting similar U.S. exports. European countries pointed out that since the U.S. controlled the reexport licensing system, American corporations could evade U.S. credit restrictions by exporting through European subsidiaries while simultaneously delaying French exports, giving American corporations a commercial advantage.[10] Specifically, non-American CoCom members felt that U.S. policies on East-West technology transfers were both volatile and politically driven, pointing to President Carter’s reversal of a denied export license for Sperry-Univac, an American corporation, to the Soviet Union—potentially because the U.S. sought a competitive advantage after deterring non-American CoCom members from pursuing similar deals.[10] Fourth, the Industrial List included “dual-use” items—goods, services, and technologies that could be deployed for both commercial and military use; however, the definition of what qualifies as “dual-use” became increasingly ambiguous. For examples, American companies exporting civilian telecommunications satellites relied upon Chinese military rockets, raising concerns about how technology transfers could enhance China’s missile capabilities.[12] Much of the opposition against CoCom revolved around whether market competition was a sufficient deterrent against exporting high-tech items to adversaries. Many European officials believed that potential competition and the risk of losing a comparative advantage would be a sufficient safeguard against Western technology transfers to the Soviets.[10] Ultimately, Cold War's end weakened the rationale for CoCom, leading to its disbandment.

Violations

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Toshiba Machine Company of Japan and Kongsberg Group of Norway supplied eight CNC propeller milling machines to the Soviet Union between 1982 and 1984, an action that violated the CoCom regulations. The United States' position is that this greatly improved the ability of Soviet submarines to evade detection. The Japanese government and U.S. House of Representatives then moved to sanction Toshiba and ban imports of Toshiba products into the U.S. military stores.[13]

In a related case, French machine tool company Forest-Liné (later acquired by Fives Group) exported tens of millions of dollars' worth of sophisticated milling machinery to the Soviet Union, allowing the Soviets to fabricate aircraft fuselages and turbine blades for high-performance jet engines. This information came to light during an investigation by the Norwegian police into the Toshiba-Kongsberg scandal. Subsequently, four top Forest-Liné executives were arrested.[14]

Legacy

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Controversies and Criticism

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CoCom’s legacy remains a subject of spirited debate and controversy. Proponents contend that it was indispensable for Western security, as it prevented advanced “critical” technologies from falling into Soviet hands and thereby bolstered the West’s strategic edge.[15][16] Critics, however, argue that CoCom’s controls were only partly effective, citing numerous breaches–with one British parliamentary review labeling the incidents a “horror story” of illegal exports–which enabled Eastern Bloc nations to acquire Western equipment despite the embargo.[15] Moreover, the regime generated diplomatic strains among allies; several partners resented Washington’s dominance and perceived double standards – exemplified by the U.S. attempt to embargo European equipment for a Siberian gas pipeline in the early 1980s, a move that backfired when it emerged that American firms had supplied similar equipment themselves.[15] By the early 1990s, CoCom was widely regarded as an outdated Cold War relic that hindered East–West economic engagement, with its eventual disbandment driven by a desire to integrate former adversaries (like Russia) into global markets and ease trans-Atlantic frictions.[17] In the 21st century, while some analysts advocate for a modern, CoCom-like coalition to restrict China’s access to sensitive technology,[16] others caution that reviving a Cold War–style embargo system would likely prove ineffective or even counterproductive in today’s interconnected global economy.[18]

Successor Export Control Regimes

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Wassenaar Arrangement

Once CoCom was dissolved, the Wassenaar Arrangement was established as CoCom’s direct successor, enabling former Eastern Bloc countries, including Russia, to join a broader global regulatory regime controlling conventional arms and dual-use technologies.[11] Rather than targeting specific countries or relying on legally binding provisions, however, Wassenaar relies on voluntary information-sharing guidelines and lacks CoCom’s ability to veto member state exports.[19][17]

The post-CoCom era has also introduced new challenges from globalization and digital technology proliferation, complicating traditional embargoes and export controls. These issues are particularly relevant with enforceable US advanced technology export controls focusing on China, which is much more integrated into the global economy today than the Soviet Union ever was.[20] Thus, contemporary U.S. export controls are more unilateral in nature, relying on comprehensive regulations that not only prohibit direct exports but also leverage globalization to control foreign-produced items incorporating U.S. technology.[21] Geopolitically, these controls aim to impede China's progress in critical high-tech sectors, bolstering U.S. technological leadership and addressing concerns about Chinese military-civil fusion.[22]

The biggest difference between CoCom and current U.S. export controls lies in enforcement mechanisms. Instead of relying on collective enforcement and potentially uneven member nation export control applications, modern U.S. policies centralize export control authority under the Department of CommerceBureau of Industry and Security (BIS).[23]BIS actively monitors compliance and has the authority to unilaterally enforce regulations and penalize violators.[24] BIS’ jurisdiction extends extraterritorially via the Foreign Direct Product Rule (FDPR), which allows the government to limit the sale of foreign-made goods that use U.S. technology.[25]

GPS “CoCom Limits"

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In GPS technology, the term "CoCom Limits" also refers to a limit placed on GPS receivers that limits functionality when the device calculates that it is moving faster than 1,000 knots (510 m/s) and/or at an altitude higher than 12,000 m (39,000 ft).[26] This was intended to prevent the use of GPS in intercontinental ballistic missile-like applications.

Some manufacturers apply this limit only when both speed and altitude limits are reached, while other manufacturers disable tracking when either limit is reached. In the latter case, this causes some devices to refuse to operate in very-high-altitude balloons.[27]

The Missile Technology Control Regime's Technical Annex, clause 11.A.3, includes a speed limit on GNSS receivers, set at 600 m/s.[28]

See also

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Further reading

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  • Casey, Christopher (2023). Export Controls—International Coordination: Issues for Congress (Report). Congressional Research Service.
  • Mastanduno, M. (1992). Economic containment: CoCom and the politics of East-West trade. Cornell paperbacks. Cornell University Press, Ithaca, N.Y. ISBN 978-0801499968
  • Noehrenberg, E. H. (1995). Multilateral export controls and international regime theory: the effectiveness of COCOM. Pro Universitate.
  • Yasuhara, Y. (1991). The myth of free trade: the origins of COCOM 1945-1950. The Japanese Journal of American Studies, 4.

References

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  1. ^ Yasuhara, Y. (1991). "The Myth of Free Trade: The Origins of COCOM 1945–1950" (PDF). The Japanese Journal of American Studies. 4: 127–148. Archived from the original (PDF) on 2004-07-30.
  2. ^ a b c Henshaw, John H. (May 19, 1993). The Origins of COCOM: Lessons for Contemporary Proliferation Control Regimes (Report). Stimson Center. pp. 1–36.
  3. ^ a b Yasuhara, Yoko (1991). "The Myth of Free Trade: The Origins of COCOM 1945–1950" (PDF). The Japanese Journal of American Studies. 4: 127–48.
  4. ^ a b c Lewis, Rand C. (June 26, 1990). "COCOM: An International Attempt to Control Technology" (PDF). Defense Institute of Security Assistance Management (DISAM) Journal. 13 (1). USA: 66–73.
  5. ^ a b c Office of Technology Assessment, Congress of the United States (1981). USA (ed.). Technology and East-West Trade (2nd ed.). Montclair, N. J: Allanheld, Osmun & Co. [u.a.] pp. 153–170. ISBN 978-0-566-00436-0.{{cite book}}: CS1 maint: date and year (link)
  6. ^ "Hotz-Linder-Agreement" (in German). Historical Dictionary of Switzerland. 2006-11-17. Retrieved 2024-04-13.
  7. ^ Christopher Casey (2023). Export Controls—International Coordination: Issues for Congress (Report). Congressional Research Service. p. 12-14.
  8. ^ Christopher Casey (2023). Export Controls—International Coordination: Issues for Congress (Report). Congressional Research Service. p. 26.
  9. ^ a b Henshaw, John H. (May 19, 1993). The Origins of COCOM: Lessons for Contemporary Proliferation Control Regimes (Report). Stimson Center. pp. 1–36.
  10. ^ a b c d e f g Lewis, Rand C. (June 26, 1990). "COCOM: An International Attempt to Control Technology" (PDF). Defense Institute of Security Assistance Management (DISAM) Journal. 13 (1). USA: 66–73.
  11. ^ a b de Salazar, Gonzalo (August 1, 2024). "Multilateral export controls: improving coordination among like-minded industrial suppliers and enhancing global legitimacy". Elcano Royal Institute.
  12. ^ Kan, Shirley A. (October 6, 2003). "China: Possible Missile Technology Transfers Under U.S. Satellite Export Policy —Actions and Chronology" (PDF). Congressional Research Service.
  13. ^ Seeman, Roderick (April 1987). "Toshiba Case—CoCom - Foreign Exchange and Foreign Trade Control Revision". The Japan Lawletter. Archived from the original on 27 September 2007. Retrieved 18 September 2007.
  14. ^ Sanger, David E. (23 April 1988). "4 in France Arrested in Soviet Sale". The New York Times. p. 37. Archived from the original on 25 May 2015. Retrieved 22 January 2023.
  15. ^ a b c "Cocom - Volume 164: debated on Thursday 21 December 1989". Hansard - UK Parliament. December 21, 1989. Retrieved 2025-03-01.
  16. ^ a b Marks, Ramon (June 22, 2023). "Commentary—Can Export Controls Win a New Cold War: A Historical Case Study". The Jamestown Foundation. Retrieved 2025-03-01.
  17. ^ a b Lipson, Michael (Winter 1999). "The Reincarnation of COCOM: Explaining Post-Cold War Export Controls" (PDF). The Nonproliferation Review: 33–51.
  18. ^ Casey, Christopher A. (September 8, 2023). "Export Controls—International Coordination: Issues for Congress". Congressional Research Service.
  19. ^ Jones, Scott (April 9, 2021). "Think twice before bringing back the COCOM export control regime". Defense News. Retrieved 2025-03-01.
  20. ^ Korhonen, Iikka (Autumn 1999). "Differences in Transition Paths: Russia versus China" (PDF). ifo DICE Report. 17 (3): 17–21.
  21. ^ Shivakumar, Sujai; Wessner, Charles; Howell, Thomas (November 14, 2022). "A Seismic Shift: The New U.S. Semiconductor Export Controls and the Implications for U.S. Firms, Allies, and the Innovation Ecosystem". Center for Strategic and International Studies.
  22. ^ "Commerce Strengthens Export Controls to Restrict China's Capability to Produce Advanced Semiconductors for Military Applications". Bureau of Industry & Security, Office of Congressional and Public Affairs. December 2, 2024. Retrieved 2025-03-01.
  23. ^ "Budget Estimates, Fiscal Year 2009, President's Submission" (PDF). Department of Commerce, Bureau of Industry and Commerce. 2009.
  24. ^ "Export Enforcement". Department of Commerce, Bureau of Industry and Security. Retrieved 2025-03-01.
  25. ^ "15 CFR 734.9 - Foreign-Direct Product (FDP) Rules". National Archives: Code of Federal Regulations. April 14, 2025. Retrieved 2025-03-01.
  26. ^ js (October 6, 2010). "COCOM GPS Tracking Limits". RAVTrack.com. Retrieved July 26, 2011.
  27. ^ Graham-Cumming, John. "GAGA-1: CoCom limit for GPS". jgc.org. Retrieved July 26, 2011.
  28. ^ "Current situation with CoCom regulations and GPS receivers for balloons and cubesats". Space Exploration Stack Exchange.