Quantum Computing Export Controls: Implications for the Health Care Sector

Quantum computers promise to create a new wave of global innovation comparable to the advent of classic computers, the internet, and artificial intelligence. Unlike classical machines, quantum computers harness the principles of quantum mechanics to process information in radically different ways — enabling them to tackle certain tasks that are difficult or impossible for traditional systems.

Like the earliest days of computing, today’s quantum computing hardware is often large and temperamental, with limited real-world application but considerable excitement about what lies ahead. In the field of health care, the potential implications are significant: from drug discovery and precision medicine, to epidemiology and public health. Many initiatives in the technology and health care sectors are exploring how quantum computing can tackle specific problems more efficiently than classical computers, such as in protein folding and computational biology.

Not only is the health care industry likely to be among those most significantly affected by quantum, we are also likely to see disruption at an earlier stage than in other sectors. By contrast, areas like cybersecurity — often highlighted as vulnerable due to quantum computing’s potential to break widely used encryption methods — are less likely to see immediate impact because the level of quantum hardware required to pose a real threat is still years away. In health care, hybrid quantum-classic approaches are already showing promise in drug discovery and drug repositioning, offering practical benefits even with today’s noisy, intermediate-scale (NISQ) quantum devices.

Chip Wars and Quantum Computers

Export controls on advanced technologies aim to prevent strategic competitors from acquiring tools and knowledge in fields deemed critical to national security and economic leadership. In September 2024, the U.S. Department of Commerce announced export controls on several emerging technologies, including quantum computers and items related to their production, research and development. Similar controls have been adopted by U.S. allies such as the Netherlands, the United Kingdom, France, Spain, Australia, and Japan.

These controls must be contextualized by two major geopolitical forces of today. First, the U.S.’ (and its allies’) strategic rivalry with China, particularly in emerging technologies such as artificial intelligence and semiconductors. The controls on quantum computing can therefore be seen as a continuation of U.S. policy to constrain China’s technological rise and preserve a strategic edge in critical industries.

And second, the weakening of international cooperation mechanisms, such as the Wassenaar Arrangement — a multilateral export control regime designed to prevent the spread of sensitive technologies — which has been undermined by geopolitical tensions, especially following the Russian invasion of Ukraine. As multilateral cooperation weakens, countries are increasingly turning to smaller, less formal groupings to set export rules — potentially introducing enforcement challenges for regulators, and compliance challenges for industry.

The form and content of the export controls threaten, or perhaps indicate, international fragmentation the development of emerging technologies like quantum computing, and the regulation thereof. This is especially significant for quantum computing because the knowledge ecosystem and supply chains are deeply international, including between Chinese and Western institutions. 

What is restricted?

The new export controls apply to advanced quantum computers and related hardware, software, materials, technology and documentation. Rather than banning trade outright, export controls introduce a licensing regime: any export, reexport, or transfer of these items generally requires government approval. License exceptions ease trade with countries that have adopted similar controls, but transfers to other destinations — including China — will face significant scrutiny.

In the U.S., sharing technology with foreign nationals within the U.S. is typically treated as a “deemed export” and therefore restricted. For now, this first round of quantum export rules — unlikely to be the last — stops short of imposing these full restrictions on foreign nationals, requiring only recordkeeping by entities covered by the rules (essentially, universities and private companies). However, some commentators suggest that future controls could impact foreign workers more directly, impacting international collaboration.

While discussions among implementing countries are confidential, it is apparent that regulators are aiming to protect quantum computers and related items at the cutting-edge or future of quantum computing development. This reflects a desire not to overburden organisations involved with systems whose underlying principles and capabilities are already well understood and accessible across international research communities. Moreover, it is notable that the rules cover a broad spectrum of the quantum computing stack and supply chain, from raw materials, to components and software, to finished products.

What are the risks and challenges of these export controls?

Current — and future — export controls could unintentionally hinder desirable international collaboration on quantum computing. Restricting the flow of knowledge, talent, and technology across borders, export controls risks encouraging siloed research ecosystems, even amongst countries that are otherwise strategic allies. This risk is heightened by the above-mentioned fragmentation in global policy on export controls.

Quantum computing also poses specific regulatory and enforcement challenges. For example, novel quantum computing breakthroughs may avoid the grasp of regulators … or otherwise outpace them. Moreover, unlike physical components, quantum software and algorithms or other intellectual property are easily shared across borders, making enforcement particularly difficult. Challenges like these have led stakeholders to question whether such controls are strategically effective, or whether they risk creating compliance burdens that slow innovation without delivering meaningful benefits.

What are the opportunities of export controls?

While there are challenges in regulating a dynamic and emerging technology like quantum computing, the flip-side is that export controls can shape the ecosystem early on, and before technology and expertise becomes widespread. Moreover, the large physical footprint of many types of quantum computing hardware makes such systems more manageable for regulators to monitor and enforce than, for instance, semiconductors.

Further, there are strategic opportunities in today’s fragmented regulatory ecosystem and quantum supply chains. Some commentators argue that traditional multilateral export control regimes — such as the Wassenaar Arrangement — are ill-suited to fast-moving technologies like quantum. Finding consensus is either slow or impossible, and implementation in participating countries varies considerably. In contrast, the recent plurilateral approach brings together a smaller group of like-minded states with interests that are more closely aligned, enabling more agile and harmonized rule-making. This model could provide tighter security coordination with greater freedom for allied collaboration when compared to the incumbent Cold War-era multilateral rules.

Conclusions

Given its disruptive potential, the health care industry should stay alert to the implications of quantum policy for innovation and access. How the quantum computing industry develops will profoundly shape who benefits — and where those benefits are felt. Recent export controls by the U.S. and its allies will play a key role in this trajectory, reflecting a fragmented global quantum value chain and signalling technological and strategic uncertainties — and opportunities — ahead.

Note: The text builds upon ideas developed in a forthcoming book chapter entitled “Regulatory Challenges and Opportunities of Export Controls on Quantum Computing”, co-authored by Peter Alexander Earls Davis, Mateo Aboy, and Timo Minssen, in Quantum Technology Governance: Law, Policy and Ethics in the Quantum Era, edited by Mateo Aboy, Marcelo Corrales Compagnucci & Timo Minssen (Springer, anticipated late 2025/early 2026). The chapter is currently available as a pre-print (open access).

This post is part of a digital symposium called Innovation, Law, and Ethics in International Bioscience. To read the related posts, click here.

Acknowledgment: This blog post was made possible through the generous support of the Novo Nordisk Foundation (NNF) via a grant for the scientifically independent Collaborative Research Program in Bioscience Innovation Law (Inter-CeBIL Program – Grant No. NNF23SA0087056).