ITIF-就_欧盟空间法_向航天商务办公室发表的评论（英）-2025.8_4页_143kb

ITIF Comments Summary on EU Space Act

The Information Technology and Innovation Foundation (ITIF) criticizes the proposed EU Space Act (EUSA) for exhibiting anti-American bias and imposing unnecessary regulatory burdens primarily on U.S. satellite and space operations. Key issues include:

• Arbitrary "giga-constellation" category: The EUSA imposes additional regulatory hurdles on satellites requiring high propellant capacity, specifically targeting U.S. companies who operate or plan constellations, without benefits to space use as a whole.

• Prescriptive reflectivity rules: These rules, which restrict satellite reflectivity to protect astronomical observations, disproportionately affect U.S. low-altitude constellations providing low-latency services, while European high-altitude constellations are less impacted. ITIF argues this stifles innovation and consumer quality, as it bans advanced technology based on current capabilities.

• Unfair market access procedures: Non-EU satellite operators face a more bureaucratic "Compliance Board" review process when entering the EU market, compared to EU counterparts, creating delays and conflicts of interest that disadvantage U.S. companies.

• Lack of proportionality in implementation: EUSA's rules start in January 2030, potentially disrupting U.S. companies already far along in developing their satellites and incurring compliance costs, whereas EU companies may develop at a slower pace.

• Launch service preferences: The EUSA gives advantages to EU launch providers, making it harder for U.S. companies to access competitive or cost-effective launch options, which harms U.S. launch providers and European customers.

Additionally, ITIF points out that the EUSA extends EU regulatory patterns seen in other acts like the Digital Markets Act (DMA), which targeted U.S. companies, and risks global spread through the "Brussels effect." ITIF concludes that opposition to EUSA's current design is necessary to protect American innovation leadership and space industry competitiveness.