Washington – The Computer & Communications Industry Association submitted comments to the Department of Commerce’s International Trade Administration in response to its request for comments on the American AI Exports Program. The filing will contribute to the U.S. government’s operationalization of the July 2025 Executive Order by the White House on Promoting the Export of the American AI Technology Stack.
CCIA’s comments highlight the importance of a flexible and proactive strategy for exporting the U.S. AI stack, which includes infrastructure, services, and devices that collectively reflect areas of strong comparative advantage for U.S. firms. The filing cautions against rigid consortium structures or an overly narrow focus on a small group of countries. Instead, it recommends a balanced approach that pairs clear regulatory guidance with engagement to address foreign digital trade barriers and targeted financing to support AI exports in mature digital economies, high-growth innovation hubs, and emerging markets.
Given that AI-enabled digital services are a core driver of U.S. exports, which generated US$729.7 billion and produced a US$282 billion trade surplus in 2024, the American AI Exports Program offers a significant opportunity to strengthen America’s technological and competitive position globally.
The following can be attributed to Jonathan McHale, CCIA’s Vice President for Digital Trade.
“The American AI Exports Program offers a chance to advance a strong and practical strategy for expanding U.S. digital services exports, and enhance a key source of U.S. global competitiveness. Our position is straightforward: the United States should adopt a flexible and expansive approach that reduces foreign digital trade barriers and leverages financing tools to unlock capital for AI deployments abroad. By doing so, the United States can accelerate the adoption of trusted American AI systems across diverse markets and ensure that U.S. technologies can compete effectively, particularly against those based in less trustworthy jurisdictions.”
