During the Biden administration’s closing days, the Commerce Department issued sweeping technology export controls, placing new limits on the export of advanced AI chips.
The rules divided countries into three tiers. The top rung, Tier 1, allows a select group of 18 US allies and partners broad latitude to import and deploy advanced AI chips. Tier 2 countries — the vast majority of the world’s nations – face much more stringent restrictions. Tier 3 — including China, Russia, and other arms embargoed countries — are effectively banned from buying cutting-edge US-made AI chips.
The Biden administration placed 17 of the 27 European Union members in Tier 2, including Poland and the Baltic states — Estonia, Latvia, and Lithuania — seemingly overlooking those countries’ deep alignment with U.S. strategic and economic goals. Warsaw and the Baltics, among others, are deeply concerned — and, some would say, furious.
President Donald Trump faces a choice. He can do away with this regulation — as some US firms and members of Congress have advocated — or leverage it to strengthen key relationships, channel allied defense spending, and protect US AI commercial interests. If President Trump keeps the rule, his administration should use the upcoming Munich Security Conference to announce Poland and the Baltics’ elevation to Tier 1 status.
Tier 1 matters. It allows streamlined access to high-performance AI chips with relatively few restrictions. License applications from these countries enjoy a presumption of approval. In essence, Tier 1 helps ensure that a country maintains reliable access to the advanced computing power needed for AI development and deployment.
It’s a no-brainer to include Poland and the Baltics in Tier 1. During his first term, President Trump found considerable common cause with them. Poland championed a vision for a robust, self-reliant Europe that invests heavily in its own defense. Leading American tech companies, from Microsoft to Google, have invested billions into Polish data centers and R&D. Microsoft and Google are expanding their support for AI innovation in the Baltics, a region already known for its advanced digital governance (Estonia), strong IT service sectors (Latvia and Lithuania), and pro-American orientation.
From a national security perspective, Poland and the Baltic states are key front-line states. They are members of key US export control systems, enjoy strong ties with US national security initiatives, and have made commitments to preventing technology diversion. Estonia leads key NATO cybersecurity and defense technology initiatives. Poland makes robust investments in defense-related AI innovation. The region’s unified stance against technology transfer to demonstrate their reliability. If these countries are placed in Tier 1, they could increase AI-driven national security spending, responding to President Trump’s repeated calls for European allies to step up on defense.
If genuine security or compliance matters exist, these should be articulated publicly and addressed cooperatively. The Trump team could work with Poland and the Baltic states to articulate security baselines that must be met to reach Tier 1.
The bottom line is that adding these nations to Tier 1 would strengthen, not weaken, the rule’s effectiveness. As the US assesses its technology relationship with Europe, Poland and the Baltic states operating could be strong partners in addressing the administration’s concerns about EU regulation of American tech companies.
At the upcoming Munich Security Conference, President Trump’s team will have a prime stage to announce that Poland, Estonia, Latvia, and Lithuania have joined Tier 1. The move would underline a strong transatlantic high-tech alliance that privileges loyal allies, encourages them to bolster defense outlays, and keeps the door open for American AI firms seeking to expand in markets primed for tech innovation. President Trump should take the opportunity to affirm America’s leadership in global AI development — and do so alongside important allies.
Pablo Chavez is an Adjunct Senior Fellow with the Center for a New American Security’s Technology and National Security Program and a technology policy expert. He has held public policy leadership positions at Google, LinkedIn, and Microsoft and has served as a senior staffer in the US Senate.
Matthew Eitel is the Chief of Staff at the Center for European Policy Analysis (CEPA).
Bandwidth is CEPA’s online journal dedicated to advancing transatlantic cooperation on tech policy. All opinions expressed on Bandwidth are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.
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