Maybe I'm Wrong About Export Controls

In Which I Change My Mind

US Export Controls for quantum computing technology and QC adjacent technology dropped a few weeks ago. I didn’t see anything materially different from what we’ve already discussed with respect to Canadian, British and EU controls.

You can find the recent US controls here¹. Search for ‘4A906’ and go to the 30th instance of that string to find the actual regulations. You may also be interested in the reporting requirements for exporting quantum technology.

Previously, I wrote

So, why all these new restrictions? Some options.

1. The bureaucrats responsible are morons and easily manipulated by $YOUR_FAVORITE_VILLAIN.
   This is not a particularly satisfying explanation for me, particularly because it short circuits all further thought.

2. The intelligence agencies involved have discovered a major breakthrough in quantum error correction and algorithms that would make a 34Q, 1e-4 error QPU plausibly dangerous.
   I don’t believe this is likely, since the rollout of these new restrictions is not EU wide, nor is it mirrored by similar restrictions in the largest QC power, the United States. Additionally, to telegraph something like this by immediately moving to export control regs with so few qubits suggests that the insight necessary is fairly obvious and might be discovered by academic or industry researchers at any time. The NSAs and GCHQs of the world are reported to have some very bright people, but do I think the QEC researchers at Google, IBM, and the universities just missed 100,000x savings in qubit count at just slightly lower error rates?

3. The bureaucrats responsible want to be seen Taking Quantum Seriously, but cynically enacted regulations that largely don’t affect their local quantum industries.
   I’m lukewarm on this option as well, for reasons similar to those stated in 1. I will note, though, that the Oxford Quantum Circuits 32Q system deployed to Japan (OQC Toshiko) falls far short of the qubit restrictions, for now. I will also note that, according to the Quantum Computing Report, Spain’s quantum industry is largely software and consulting. Their best known quantum computing hardware company, Qilimanjaro, is pursuing high-coherence quantum annealing, which is specifically exempt from these restrictions. On the other hand, Oxford Instruments is a well known dilution refrigerator manufacturer which offers systems that seem to be impacted by the export controls. This is odd to me, as Finland⁷ has not made any changes to its export regime for dil fridges as far as I can see. Nor has the Netherlands⁸.
   However, ASML is THE fabrication tooling manufacturer for semi-conductors, so these restrictions on cryoCMOS equipment seem like they will be meaningful for the Netherlands. On the other hand, perhaps these restrictions are basically OK, since ASML is not a chip manufacturer and presumably they’d get an export license to sell machines to the USA. Maybe not to China, though?

4. A fourth, mysterious option.
   Maybe I’ll think of something better.

Today I would go with Option 4:

It’s hard to predict technological progress and what the Decision Makers have seen so far + conversations with the major players in the field lead them to decide on regulating sooner rather than later.

In the last year we’ve seen: some nice papers demonstrating error correction from Google and AWS², plus another paper from Craig Gidney claiming to have killed magic state distillation, reports from Quantinuum and Google³ that they’ve achieved < 1e-3 average CNOT error in some of their systems, plus high fidelity SPAM from Oxford Ionics, plus probably a bunch of stuff I’ve forgotten. PLUS, the academic labs are edging 1Q gates with 5 9’s fidelity. 2024 has been a pretty impressive year for QC, and it’s not over.

We know that these rules have been under consideration for several years, and the government claims that affected parties have been invited to comment on earlier versions of these controls. It doesn’t seem far-fetched that some Decision Makers got tours of Google/Quantinuum/IBM facilities and had some NDA’d conversations about near- and medium-term progress. With some pragmatism about the realistic speed of government actions in this (or any other space) and humility about the rates of technical progress and unknown unknowns, I don’t think it’s unreasonable that you end up deciding to put in restrictions that seem premature because you know the alternative is that FedGov ends up way behind the curve on this.

I still think this sucks for QC startups that might have foreign employees, but my initial reaction that this regulation is dumb and bad was wrong.

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1. h/t Travis Scholten

2. You might also be interested in this related paper from AWS about the hardware implementation

3. I don’t have a real ref for this. Saw some slides from an informal talk Hartmut Neven(?) was giving.