Over the past four years, Washington’s foreign policy establishment has stumbled on a new arena for competition with China: international technical standards. During that time, standards have been the focus of news stories, think tank reports, and even several pieces of federal legislation. Across these, the master narrative is largely the same: technical standards are a key part of technology competition, China is taking over international standards bodies, and it is successfully manipulating those standards as part of its quest for global tech domination.
Parts of that narrative ring true. Technical standards are a critical part of the global technology ecosystem because they facilitate trade, can give first-movers a competitive advantage, and can generate significant revenue for companies with large patent portfolios. The Chinese government has a track record of trying to manipulate international organizations, and Chinese participation at international standards bodies is increasing.
But Washington’s master narrative around technical standards is wrong. It’s not wrong because the Chinese Communist Party is a trustworthy actor in these arenas—it isn’t. The narrative is wrong because it fundamentally misunderstands what international technical standards do and how standards development organizations (SDOs) operate. There are real concerns when it comes to China and technical standards, and those concerns require targeted actions. But to make the right prescription, the U.S. policy community must first correctly diagnose the problem.
Despite China’s growing presence, the international standards regime remains quite robust. The quality of governance varies from SDO to SDO, but standards participants agree that, by and large, the system remains in a good place. Given that robustness, there’s currently more risk if the U.S. government tries to disrupt the system—particularly by pulling public funding or banning Chinese participation—than if it trusts SDOs to continue their work. Instead, the government should focus its attention on bolstering U.S. actors’ participation in those SDOs.
What Are Technical Standards?
Technical standards are the detailed specifications for how pieces of technology should be built so that they meet performance thresholds and can connect to other products. This ability to interface between two products, known as interoperability, applies to both physical and digital aspects. For example, international standards for the dimensions of shipping containers are what allow them to be neatly stacked, easily lifted, and quickly loaded onto ships traveling worldwide. On the software side, to load this web page, your computer and the server communicated with one another using the foundational TCP/IP standard.
These kinds of standards are effectively public goods: they grease the wheels of the global economy, helping facilitate trade and information sharing. Standard setting acts like an intermediary layer within markets, a semiformal process of communication and consensus-building that reduces some of the inefficiency and friction that would come from each company simply throwing their products onto the market and letting them compete.
When standards are widely agreed upon internationally (think, the internet), they allow for seamless global communication and lower costs. When countries or companies can’t agree (think, power outlets), they force the duplication of products and annoyance for normal people trying to charge their phones.
How Are Standards Set?
Technical standards are set by an alphabet soup of national and international SDOs. Some SDOs focus on a specific geography or country, while others aspire to set global standards. Some focus on certain technologies, such as the 3rd Generation Partnership Project, which sets mobile broadband standards. Others, such as the International Organization for Standardization, have hundreds of technical committees that work on technologies as diverse as autonomous vehicles and sewing needles.
When there is a need for a new standard, SDOs form technical committees and working groups that bring together engineers, researchers, academics, and, in some cases, public officials. These experts introduce proposals for the standard that they then debate, tweak, compromise on, and eventually decide on. Sometimes these decisions are made by voting; others are made only when consensus is reached. In a well-functioning SDO, this hashing out of proposals is done in a transparent manner. This process is often mind-numbingly technical and can stretch from eighteen months to three years or longer.
Most international SDOs share a set of core principles. The decisions they make are industry-led and consensus-driven, and the standards they create are voluntary, or nonbinding. These principles form the basis of good standards-setting, and they are the reason that well-run SDOs today remain largely robust to attempts at manipulation by bad actors. The industry-led and consensus-driven nature of standards means no single faction can force their preferred vision upon the group. More importantly, the voluntary and nonbinding nature of standards means that even if bad actors do manage to get a bad standard through, they can’t force companies or countries to use it. Sometimes, when participants are unable to reach consensus on a standard, they will approve multiple standards, leaving market forces to pick the winner. Ultimately, if a standard is not useful to the industry, the key players will ignore it and build things in a different way.
Still, when a technical standard is adopted, it can impact both corporate and geopolitical power. When a company succeeds in making its own patented technology the globally adopted standard, it wins two rewards: it gains a first-mover advantage and can rake in royalties on patents that are deemed “standards-essential.” Countries that are responsible for larger shares of the IP baked into standards will accrue these two benefits at scale.
China’s Role in International Standards
International technical standards would not be on most policymakers’ radars if it weren’t for China’s growing presence in these activities. Over the past fifteen years, Chinese private- and public-sector stakeholders have increasingly participated and assumed leadership roles in international SDOs. In the International Organization for Standardization (ISO), one of the largest standards organizations, China has expanded the number of technical committees and subcommittees it participates in, from 465 in 2005 to 668 in 2021. That ranks it third in total committee participation, behind the United Kingdom and Germany. In terms of leadership of standards committees, China held sixty-nine ISO secretariats in 2021, slightly less than its 2016 total and ranking in sixth place behind Germany, the United States, the United Kingdom, France, and Japan. China doesn’t dominate these organizations by sheer numbers, but it does play a large and growing role, particularly in strategic technology sectors such as 5G.
This is happening against a backdrop of a Chinese bureaucracy that is increasingly focused on technical standards. Since 2014, the Chinese government has been revamping its standards development process, both increasing industry participation and identifying standards as a key area for policy support. It perceives standards development as of strategic importance to China’s technology innovation and has acted accordingly to bolster those systems. In 2018, the Standardization Administration of China launched a research project known as “China Standards 2035,” which offered recommendations for how China could improve its standards-setting process. While the project’s title echoed the much-maligned “Made in China 2025” initiative, the actual recommendations leaned toward a strengthened role for industry within a state-guided standards system. Those recommendations, however, led to intense infighting within the Chinese bureaucracy and were never fully adopted. In a 2021 outline for national standards development, the central government described standards as a tool to “promote industry optimization and upgrading” and called for 85 percent alignment between domestic and international standards. (The goal of 85 percent alignment remains unrealistic for the foreseeable future.)
Growing Chinese government interest and industry participation in standards committees alone aren’t reasons for alarm, but widespread attempts to manipulate those standards bodies would be. In recent years, reports have documented attempts by Chinese actors to alter the outcomes of standards votes, including by demanding that all Chinese participants on a given committee vote for one proposal. In 2021, the Wall Street Journal reported that in two meetings related to telecom standards, Chinese participants were told that they had to vote for Huawei’s proposal, a blatant violation of the norms and rules for SDOs.
China’s growing presence in standards meetings and these instances of attempted manipulation raise the following questions: Are Chinese abuses or attempts at manipulating standards widespread? When there are attempts at manipulation, are they successful? And if this type of manipulation is successful, how can policymakers and the standards community best combat it? The rest of this piece seeks to answer these questions.
Are Chinese Attempts at Manipulation Widespread?
Technical standards are kaleidoscopic in their diversity and specificity, making any all-encompassing assessment near impossible. But based on publicly available surveys and conversations with participants in standards-setting committees, it appears that attempts by Chinese actors to manipulate standards are not widespread. This remains a tentative conclusion, and confirming it requires more data gathering and coordination between actors.
In gathering data on this question, we surveyed the submissions by fifteen U.S.-based private-sector organizations—most of them industry associations that represent many members—to a Request for Information made by the National Institute of Standards and Technology (NIST). NIST asked commenters to assess the scope and potential value of Chinese participation in international standards, as well as whether those standards were being designed to benefit China. We found that most industry commenters do not believe that China is manipulating or breaking the rules of international SDOs. Of the fifteen submissions, which were made public in December 2021, only one described an instance of undue influence by Chinese actors, while two more asserted that the concern existed. However, the submissions shouldn’t be taken as the final word. Organizations submitting responses could have hesitated to call out instances of manipulation, fearing backlash in China or an overzealous and counterproductive policy response from the U.S. government.
But the findings line up with what American standards professionals have described in private conversations: the reported incidents of Chinese manipulation are the exception rather than the rule. These standards professionals say that Chinese participants usually act within the existing norms and rules of standards bodies. In some cases, those Chinese participants are very well-resourced and produce good submissions, and in others, they produce weak proposals that are quickly dismissed by the group. But looking across a wide range of industries, they do not appear to regularly act in highly strategic, coordinated ways to give Chinese companies or standards proposals unfair advantages.
Given the sprawling nature of standards and the limited windows into these processes, more data and continual monitoring are needed to better assess this question and ensure that any changes to the status quo are recognized immediately.
Are Attempts at Manipulation Successful?
When a bad actor attempts to force through a bad standard that unfairly advantages them, they face two hurdles: getting the standard passed and getting it adopted. Both of these hurdles stem from SDOs’ core principles of consensus-driven standards setting and voluntary enactment.
Forging consensus among technical experts at SDOs requires extensive research, rigorous debate, and frequent compromise. For important standards with widespread participation, a single company or country is not able to bulldoze their peers and force through harmful standards. Furthermore, as the number of participants in a committee grows, the voting power of each participant declines. There have been media reports of Chinese participants voting as a bloc, but as noted above, these examples appear to be the exception, and they tend to occur in SDOs where membership is government-based, such as the International Telecommunication Union.
Exactly how difficult it is to force through a nonconsensus standard depends on the specific rules of the SDO in question, but at the most respected and influential standards institutions, the rules remain relatively robust. At the ISO, for example, reaching consensus on a standard is a long and cumbersome process that heavily prioritizes due process over speed. The ISO and other older SDOs are typically more robust because they have made fewer sacrifices in the name of speed. And in general, due process rules at SDOs already border on onerous.
The final, and the most important, backstop against successful manipulation is the nonbinding nature of most international technical standards. At most international SDOs, technology standards are generally not laws or rules that everyone must follow. Domestic standards in the European Union and China are sometimes incorporated into regulation, but for the United States and for the large majority of international SDOs receiving attention today, standards are mutually agreed upon, nonbinding guidelines. When there is insurmountable disagreement in a standards committee—perhaps because one faction is pushing an unpopular proposal—SDOs can publish multiple options and let the market choose a winner. This is what happened with the ISO’s technical committee on shipping containers.
And, importantly, if a bad actor manages to force through a bad standard for a given technology, the rest of the industry will simply ignore it in most cases. This has been the case for many standards emerging from the United Nations’ main standards body, the International Telecommunication Union’s Telecommunication Standardization Sector (ITU-T). Participants frequently complain that the ITU-T’s procedures and protections aren’t rigorous enough, allowing standards decision to be driven by geopolitics. Chinese participants are said to make dozens of low-quality proposals in ITU-T subcommittees, often simply because they can collect government subsidies for each international standard proposed or set. As a result, many commercial actors have stopped participating in or adhering to ITU-T standards. Firms’ lack of trust in the ITU-T is damaging the general reputation of international standards development, but the ITU-T’s frailty is not step one on China’s path to world domination.
Does China Use the Belt and Road Initiative to Lock Countries Into Its Standards?
Analysts have repeatedly warned that China is using its activities through the Belt and Road Initiative (BRI), and the accompanying Digital Silk Road, to lock countries into using Chinese standards. China’s 2021 national standards strategy called for increasing standards interoperability and cooperation along the BRI. In this vein, package funding deals offered by Chinese railroad companies to BRI countries often require the use of Chinese standards, whether they are de facto standards (that is, simply embedded in key products) or de jure ones endorsed by an SDO. In these instances, Chinese companies could be the only ones with equipment built to that standard, forcing recipient countries to rely on Chinese companies to maintain the railroad.
The extent of this issue remains unclear, as does the centrality of the standards themselves to the problem. Critics often point to the fact that China has signed many memorandums of understanding with BRI countries calling for mutual recognition of standards, but these are largely ceremonial and, in the opinion of Chinese standards experts, have “no substance.” When looking for documented cases of Chinese companies using standards to lock in BRI countries, examples are hard to come by, aside from a handful of instances of Chinese companies building railways overseas. This could reflect a lack of publicity of a widespread problem, or it could signal that this phenomenon is not as acute as imagined.
The Real Problems with China and Standards
Most concerns center on the idea that China is manipulating standards and using them to force its technologies—and values—on the rest of the world. This type of manipulation appears to be rare and largely unsuccessful. But China can manipulate international standards for other purposes, and it poses broader challenges to the standards system.
For example, China has used international standards to cover up unfair domestic protectionism. The World Trade Organization’s Technical Barriers to Trade agreement is intended to prevent countries from using domestic technical standards as a way to advantage local firms. It does so by requiring member countries to use international standards rather than domestic ones that if standards drive determinations of which products can enter their domestic market. But that mechanism only works if the main SDOs are producing fair, consensus-driven standards. Given the weaknesses of the ITU-T, China can push its own domestic standards through the body, and then require that all companies in its domestic market use the “international” standard—disadvantaging foreign companies.
Separately, the Chinese government grants subsidies to firms for each proposal they submit to international SDOs. This has led to a flood of low-quality proposals from Chinese companies looking to cash in. Although the proposals are often quickly shot down, the sheer quantity gums up the workings of SDOs. In some instances, this has led U.S. companies to withdraw from bodies where this behavior is common, such as the ITU-T.
In other cases, the government provides extensive resources to Chinese participants in international standards bodies. Drafting a strong standards proposal is a time- and labor-intensive process, and the participants who produce early drafts often have an outsized impact on the final standard. By providing companies with the funds and technical talent needed to draft strong proposals, the Chinese government gives these companies a running start at international SDOs. Neither of these behaviors necessarily violates the rules of SDOs, though this can be the case. But they do alter the landscape of international standards in a way that requires a response.
Some scholars point to a deeper concern: even if China is playing by the rules, the fact that it is gaining influence contributes to the overall power of the Chinese party-state. That power manifests in the form of revenue from standard-essential patents, greater switching costs for companies, and, in some instances, the indirect embedding of values into technical parameters. While Chinese participants in SDOs may represent private companies, they remain embedded within a mixed economic and political system, and one in which the Chinese party-state uses standards as part of its industrial policy. These are important considerations for understanding both the role of standards in geopolitical power and the unique concerns when dealing with China. How concerned international actors should be over China’s growing standards power, and what role international SDOs should play in mitigating such power, remains a matter of debate.
What Should Be Done?
Regardless of how worried one is about China’s growing standards power, the policy prescriptions remain similar. American and European standards experts—those in the trenches of actual standards-setting work—agree that attempting to summarily exclude China from international SDOs would likely be a death knell for the international technical standards system and all the benefits it brings to the world economy. Instead, defenders of technical standards should seek to identify and eliminate bad behavior where it exists, and bolster the competitiveness of American standards participants, particularly those who have historically struggled to participate in international standards development.
The U.S. government response, in particular, should involve three key components: assessment, vigilance, and engagement. While assessment and vigilance can target unfair practices and attempts at manipulation, engagement can bolster the competitiveness of American participants in the standards system.
Assess Chinese Manipulation Efforts and Remain Vigilant
The United States and its allies should gather data to assess how frequently and how successfully Chinese participants manipulate SDO processes and in what technical areas. Based on public comments and private conversations with standards participants, we assess that the frequency and success rate of manipulation attempts are low. But that conclusion needs to be tested in a more systematic way, such as through a wider survey of standards participants. More respondents reporting successful manipulation efforts would call for a much stronger policy response. A survey would also help determine which SDOs are more at risk of Chinese manipulation. Designing and executing such a survey would be difficult because of the vast number and high diversity of SDOs, as well as the mixed incentives for those organizations to participate. Some of these hurdles might be overcome by administering the survey directly to standards professionals (rather than through SDOs), perhaps in partnership with the American National Standards Institute or relevant industry associations.
With data in hand, the United States and its allies should build national and international platforms to share information and track attempted manipulation or abuse. While most SDOs are currently robust, the system itself is valuable enough to warrant ongoing monitoring. Chinese manipulation aside, a monitoring effort should also track how the U.S. and allied governments are engaging with international standards committees. This will be essential for identifying specific standards where governments should engage more closely and what type of in-house technical expertise governments will need to curate. Any such platforms should work closely with the SDO community. This could involve a multilateral partnership to monitor SDO activity and flag potential manipulation—building off high-level standards initiatives announced in May 2022 at the Quad Summit and the U.S.-EU Trade and Technology Council.
Boost U.S. Engagement at SDOs
The United States should seek to bolster participation of civil society and small and medium-sized enterprises (SMEs) in international standards development. One of the standards system’s greatest strengths is that it seeks to draw on expertise from around the world and from many different perspectives. Unfortunately, that’s mostly aspirational because engaged participation at international SDOs can have high barriers to entry. One estimate suggests that it may cost a company more than $300,000 per year to pay for one standards engineer to participate in SDO technical committees. The price tag essentially limits engaged participation to large corporations.
The United States doesn’t need to mimic the Chinese approach of throwing resources at companies to encourage their participation in SDOs. But it should ensure that representatives from all parts of American society can participate. To do so, the U.S. government should take three steps: (1) subsidize the travel and salary costs for SMEs and civil society to participate in SDOs, (2) expand tax breaks for research and development to cover international standards development expenditures, and (3) make it much easier to hold international standards meetings in the United States via fast-track visa processing for foreign participants. For the first of those three steps, the 2022 CHIPS and Science Act initiated a pilot program that still requires funding; the visa concerns remain unaddressed.
Prioritize High-Stakes Industries
When prioritizing its limited monitoring resources, the U.S. government should consider that the stakes are higher for standards setting in some technology areas than others. Standards for 5G communication and other fast-evolving fields are far more critical to national security than those for legacy industries. Furthermore, while standards are voluntary, since interoperability is essential to telecommunications, it would be difficult to switch away from the industry consensus on 5G standards. SDOs that are particularly susceptible to manipulative behavior, such as ITU-T, also deserve heightened attention.
Conclusion
Technical standards and SDOs are in a tough spot. They have long functioned behind the scenes, quietly going about their work of facilitating trade, expanding information flows, and increasing safety. Thrust into the policy spotlight, SDOs now face two potential challenges: one from a Chinese bureaucracy that is increasingly focused on bolstering the country’s participation and the other from a U.S. government whose overreaction to China’s activities could undermine or disrupt relatively robust standardization processes.
Threading this policy needle will require the U.S. government to approach the problem with appropriate humility about what it knows and what role it should play. This can begin with conducting a wide survey of standards participants to assess the problem; proceeding with vigilance through ongoing monitoring for violations; and ultimately, pushing for greater engagement from all corners of the technology landscape. If executed well, these moves can further strengthen and ensure the lasting integrity of international technical standards.
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