Submission to the European Commission on dual-use R&D funding

30 April 2024

Submission to the European Commission on dual-use R&D funding

1. The Irish Council for Civil Liberties (ICCL) is Ireland’s oldest independent human rights organisation. We welcome the opportunity to provide feedback on the European Commission's White Paper ‘On options for enhancing support for research and development involving technologies with dual-use potential’.[1]
   
   
2. Currently, the European Union has two main research funding instruments. Horizon Europe for exclusively civil applications,[2] and European Defence Fund (EDF) for exclusively defence related activities.[3] The success of Horizon Europe requires a “strong engagement of industry and civil society”[4] with some of the funds distributed to civil society organisations part of projects.
   
   
3. The European Commission wants to increase cross-fertilisation of research carried out under these funding regimes on technologies with dual-use potential,[5] and proposes three options:
   
   
   1. Keep the current funding instruments and make incremental improvements;
   2. Remove the exclusive focus on civil applications in selected parts of the successor of Horizon Europe; and
   3. Create a dedicated instrument with a specific focus on R&D with dual-use potential.
      
      
4. ICCL urges the Commission to choose Option 1 and strongly opposes Options 2 and 3. We provide additional considerations below:
   
   
5. Research and innovation are best served by encouraging open science and international cooperation.[6] This will not be possible with Options 2 and 3. Instead, these routes would restrict information exchange between countries, and even within organisations where an organisation performs research on both civilian applications and defence applications.
   
   
6. The proposed dual-use flagging mechanism in Option 1 should be complemented with a comprehensive assessment of projects that could endanger the EUs obligations under international humanitarian law, and include human rights and environmental impact assessment.
   
   
7. Option 2 will normalise military research at academic institutions and will dissuade civil society organisations from engaging in joint-research projects with such institutions and undermine future Horizon Europe programmes.
   
   
8. Finally, budgetary transfers between Horizon Europe and EDF is currently not allowed.[7] This should remain unchanged.

Sincerely,

Dr Kris Shrishak
ICCL Enforce Senior Fellow