# Coordinating Committee for Multilateral Export Controls

The Coordinating Committee for Multilateral Export Controls (CoCom) was established in 1949 at the beginning of the Cold War to coordinate controls on exports from Western Bloc countries to the Soviet Union and its allies. CoCom ceased to function on March 31, 1994, but the control list of embargoed goods was retained by the member nations until the Wassenaar Arrangement was established in 1996.

## Origins and Historical Context

CoCom originated from the tense geopolitical atmosphere post-World War II, as Western nations grew wary of advanced technology potentially reaching the Soviet Bloc, aiming to collaborate on limiting technology transfers to the East. Many of these concerns stemmed from America’s substantial investment in Japan during the 1930s, which, ironically, led to Japan's swift rise and subsequent dominance in East Asia leading to World War 2. In the light of the Soviet Union’s inaugural nuclear test in 1949, confidential discussions took place between the United States, United Kingdom, and France, laying the groundwork for a coordinated effort to embargo critical exports to communist nations. These discussions resulted in a covert “gentlemen’s agreement,” which established CoCom in late 1949, with operations beginning in early 1950.
Nonetheless, CoCom encountered initial hurdles in fully establishing the organization through a multinational treaty, as their controls did not supersede unilateral treaties. Instead, decisions on the restriction of certain exports were made based on unanimous consent, which diminished the organization’s effectiveness. Consequently, in 1951, the U.S. enacted the Battle Act to encourage participation, threatening to cut aid to allies engaging in trade with communist nations. 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.
In the 1980s, there was a resurgence of interest in CoCom. With the United States facing more global competition in technological development, European nations questioned the strict export restrictions and often lax enforcement, with many members believing that trade limitations were dictated more by foreign policy considerations than by genuine national security concerns. 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 commitments to the CoCom. Nearly all countries in NATO joined CoCom, while tighter licensing and enforcement measures were adopted, with military advisors able to provide recommendations regarding certain technologies. These initiatives laid the foundation for enhancing the reliability and effectiveness of the CoCom organization.

## Membership

In its final years, CoCom had 17 member states:
* Australia
* Belgium
* Canada
* Denmark
* France
* Germany
* Greece
* Italy
* Japan
* Luxembourg
* Netherlands
* Norway
* Portugal
* Spain
* Turkey
* United Kingdom
* United States
Despite being neutral, Switzerland joined the CoCom sanctions against the Eastern bloc countries; see Hotz-Linder-Agreement [de].

### Laws and regulations

In the United States, CoCom compliance was implemented by various statutes authorizing the President to regulate exports, 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. However, throughout the Cold War, the United States maintained controls in excess of those agreed to in CoCom.
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

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. Moreover, the export control lists were successfully updated in 1954, 1958, 1961, 1964, 1967, 1971, and 1974-1975 to reflect revisions in relations between CoCom constituents and the USSR. President Bush’s successful proposal to eliminate a significant number of industrial and dual-use export controls under CoCom, following the fall of the Berlin Wall and the diminished Soviet influence in Eastern European governance in 1989, reflects CoCom’s adaptability to changing geopolitical climates. Moreover, in 1992, CoCom members collectively agreed to expand membership to the former USSR. The longevity of CoCom—lasting 30 years despite military risks that threatened its abolition—could also be considered a success.
However, there were significant limitations to the enforceability of CoCom’s export controls, as well as ambiguity surrounding the lists themselves. First, CoCom had a team of only 14 overworked staff members in the 1980s. Poor enforcement of export controls was reflected in the lack of a synchronized technology transfer policy from the West to the East due to CoCom members’ inability to agree on which nonmilitary technologies should be restricted. Second, CoCom not only lacked large fines for violators but was also unable to impose sanctions against them. Third, there were frequent complaints about American hypocrisy within CoCom, with European countries pointing out that American corporations could evade U.S. credit restrictions by exporting through European subsidiaries while simultaneously delaying French exports through U.S. control over the reexport licensing system, giving American corporations a commercial advantage. 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.
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. This issue was highlighted by controversies over American companies exporting telecommunications satellites, as these civilian satellites were launched using Chinese military rockets, raising concerns about how technology transfers could enhance China’s missile capabilities. Much of the discourse about alternative solutions to CoCom revolved around whether commercial rivalry itself could serve as a deterrent against exporting sophisticated technologies to the USSR. 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. Ultimately, the end of the Cold War made CoCom’s dissolution inevitable, as its existence depended primarily on embargo policies against the USSR and its allies.

## Violations

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. Congress moved to sanction Toshiba and ban imports of its products into the United States.
In a related case, French machine tool company Forest-Liné (later acquired by Fives Group) exported several machines, used for fabricating 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.

## Controversies and Criticism

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. Critics, however, argue that CoCom’s controls were only partly effective, citing numerous breaches – with one parliamentary review labeling the incidents a “horror story” of illegal exports – which enabled Eastern Bloc nations to acquire Western equipment despite the embargo. 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. 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. In the 21st century, while some analysts advocate for a modern, CoCom-like coalition to restrict China’s access to sensitive technology, others caution that reviving a Cold War–style embargo system would likely prove ineffective or even counterproductive in today’s interconnected global economy.

## Legacy
### GPS

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

## Comparison with Successor Export Control Regimes

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. 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.
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. 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. 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.
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 Commerce’ Bureau of Industry and Security (BIS). BIS actively monitors compliance and has the authority to unilaterally enforce regulations and penalize violators. 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.