First of all, I really welcome this feature and the great detailed explainer.
In the line of, now postponed declarative shadow dom, I believe HTML modules to become popular by designers etc, at least if they can stay within the realm of HTML and CSS and thus avoid "coding" JavaScript. I think it is valid to consider this case and I see that there is already an issue filed about a declarative way to export (https://github.com/MicrosoftEdge/MSEdgeExplainers/issues/9).
As you allow multiple exports (like ECMAScript Modules), this makes it a valid target for dead "code" elimination and "code" splitting (dead content elimination and content splitting? :-)) - I don't know what is needed to make that work well, but I believe it is important to consider, especially because if it is not possible, you will see developers arguing for just using scripts instead (CSS-in-JS etc)
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