The U.S. National Science Foundation (NSF) recently issued a "Dear Colleague" letter, announcing plans to introduce a so-called new "research security policy" in fiscal year 2027. Citing concerns including "national security," the proposed policy would prohibit NSF-funded projects from collaborating with entities listed on what it describes as U.S. "Restricted Party Lists," including the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Entity List, the Department of Defense's Section 1260H list, and the Federal Communications Commission's (FCC) Covered List.

The proposed restrictions are broad in scope and stringent in nature, targeting both institutional cooperation and individual researchers. At the institutional level, NSF funding would not be allowed to support any form of collaborative research between NSF-funded projects and "restricted entities," nor would cooperation with employees of such entities be permitted. At the individual level, NSF-funded "senior/key" personnel would be barred from holding any position or appointment at a "restricted entity," receiving research funding from such entities, or collaborating with them or their employees on NSF-supported research.

Although the policy does not explicitly name any country, China is clearly its primary — and arguably only — target. The BIS Entity List includes hundreds of Chinese technology companies and leading universities and research institutions. Most entities on the FCC Covered List are Chinese technology companies or their products, while the Department of Defense's Section 1260H list was created specifically to identify Chinese military companies, including major Chinese technology firms such as Baidu and BYD.

The day after the NSF announcement, John Moolenaar, who chairs the U.S. House Select Committee on China, said that "prohibiting federal funding from being used to collaborate with Chinese entities that are national security risks or human rights abusers is straightforward and all federal agencies should follow the lead of the Pentagon and NSF."

However, neither the BIS Entity List nor the Section 1260H list currently prohibits scientific cooperation with Chinese entities. The NSF's proposed policy would significantly expand the scope of these restrictions by extending national security considerations into the field of academic research.

For example, the U.S. Export Administration Regulations explicitly state that information resulting from basic or applied scientific and engineering research is exempt from export control laws and regulations. As a result, BIS restrictions do not provide a legal basis for banning scientific cooperation such as jointly publishing academic papers.

Similarly, the Department of Defense's Section 1260H list primarily restricts listed entities from participating in U.S. military supply chains; it does not prohibit civilian scientific cooperation unrelated to the Department of Defense.

The FCC Covered List limits certain companies' products and services from entering the U.S. market, but it does not impose restrictions on academic research collaboration.

As one of the largest U.S. research funding agencies, the NSF plays a central role in supporting basic research. Its funding accounts for roughly one-quarter of federal government support for basic research at U.S. universities. If implemented, the proposed policy could significantly damage international scientific cooperation between the U.S. and China.

Hundreds of Chinese technology companies, universities and research institutions could be excluded from NSF-funded international research programs, making it difficult for them to collaborate with U.S. scientists receiving NSF support. And this would represent only the immediate impact.

More importantly, as a government agency with substantial influence over the distribution of research funding, the NSF's decision could create a broader "chilling effect" across the U.S. academic community. Universities and researchers may become increasingly cautious about engaging with Chinese partners, affecting even projects that do not involve NSF funding or entities listed on U.S. restriction lists.

Ultimately, NSF's expansion of national security restrictions into scientific collaboration risks harming U.S. interests as much as those of China. Experience has already shown that attempts to contain China's technological development through scientific decoupling are unlikely to succeed.

Both the U.S. and China are among the world's leading contributors to scientific research. Scientific cooperation between the two countries benefits not only their own technological advancement but also global scientific progress and human welfare.

As a major U.S. institution supporting fundamental research, the NSF should serve as a facilitator — rather than an obstacle — of international scientific collaboration. The proposed China-related restrictions should not be allowed to undermine decades of productive scientific exchange or produce consequences that ultimately harm all sides.