Manufacturers caution that Biden’s chemical ban could make US military dependent on China
EPA Proposal Threatens National Security by Reliance on Foreign Materials for Military Gear
A Biden administration proposal to effectively ban a chemical used to produce U.S. military equipment would make America’s national defense apparatuses reliant on China and other foreign sources, domestic manufacturers are warning.
President Joe Biden’s Environmental Protection Agency last year unveiled rule proposals aimed at banning certain chemicals under the Toxic Substances Control Act. At least one chemical on the chopping block—methylene chloride—is used to produce military equipment such as bulletproof glass, helmets, and fighter jet canopies. As a result, companies that rely on the chemical to produce such products are sounding the alarm, with polymer manufacturer Covestro arguing in a June letter to the EPA that the ban would “require military and police related applications to be manufactured from foreign sourced materials.”
The proposed ban comes as China works to ramp up its chemical production. While the communist nation controlled just 9 percent of the world’s chemical sales in 2003, it is now the largest chemical producer in the world, accounting for 44 percent of global sales as of 2022. That year, China was one of the world’s top exporters of carbon tetrachloride, which is used to destroy chemical weapons. China is also the world’s top exporter of methylene chloride, which the Department of Defense also uses to make specialty batteries and remove paint from aircraft, among other manufacturing purposes.
The department under Biden has worked to build up the domestic production of “high priority chemicals” in an attempt to reduce “foreign dependency for critical materials required for DoD missiles and munitions.” To remain in line with that mission, the EPA generally issues national-security-related exemptions on its environmental regulations.
At least one company, however, is arguing that even with those exemptions, the Biden administration’s methylene chloride ban would impact the supply chain for military equipment.
Chemical manufacturer Nalas Engineering Services inked a $2 million deal with the Department of Defense in 2022 to “strengthen the domestic critical chemicals industrial base” and, as it wrote in a July letter to the EPA, is subsequently allowed to use banned chemicals “that are critical to the support of national security.” The company nonetheless argued in the July letter that a methylene chloride (DCM) ban would throw a wrench into its supply chain.
“Nalas manufactures chemicals that are critical to the support of national security. As such, Nalas’ processing of DCM is a specifically allowable condition of use per the proposed rule,” the company wrote. “However, Nalas is concerned that the additional proposal constraints—which prohibit uses that account for roughly a third of current DCM production—will have long term supply chain implications.”
Another chemical manufacturer, Boulder Scientific Company, echoed those concerns, writing in its July response to the EPA that a methylene chloride ban could force large chemical producers “to seek suppliers of chemicals from non-domestic sources.”
The EPA did not respond to a request for comment.
This is not the first time the EPA’s proposed ban has attracted national-security-related concerns. In September, a Department of Energy laboratory blasted the agency’s proposed methylene chloride ban, arguing that the move would hinder the lab’s ability to detect weapons of mass destruction and conduct “complex” national defense research.
“[The laboratory] is concerned that the availability of methylene chloride from vendors and distributors for these important DOE mission research purposes will be limited or non-existent,” the lab wrote in a letter.
How does the EPA’s proposed ban on methylene chloride impact the Department of Defense’s efforts to promote domestic production of high-priority chemicals
A LinkedIn post, the ban on methylene chloride “could severely restrict or eliminate the ability of U.S. businesses to supply critical DoD requirements for domestic delivered chemicals.”
These concerns highlight the potential national security implications of the EPA’s proposal. The reliance on foreign sources of materials for military gear raises serious questions about the resilience and independence of America’s defense apparatuses. A heavily dependent supply chain can create vulnerabilities and expose the country to risks, including disruptions in the event of geopolitical tensions or trade disputes. It also undermines the United States’ strategic advantage and jeopardizes its ability to respond effectively to national security threats.
China’s dominance in the chemical production industry is a significant factor contributing to these concerns. With its increasing control and market share, China has become the largest global producer of chemicals, including those essential for military equipment production. The country’s status as a top exporter of carbon tetrachloride and methylene chloride further amplifies the issue, as these chemicals play vital roles in various defense-related applications. By relying on China for critical materials, the United States becomes vulnerable to potential supply disruptions and compromises that could impact its military capabilities and readiness.
Recognizing the importance of reducing foreign dependency, the Department of Defense has taken steps to promote domestic production of high-priority chemicals. The Biden administration’s efforts to strengthen the domestic critical chemicals industrial base align with the goal of reducing reliance on overseas sources for essential defense materials. However, the EPA’s proposed ban on methylene chloride poses a significant challenge to these efforts. Even with national security exemptions, the ban would disrupt the supply chain and force manufacturers to seek materials from foreign sources. This undermines the administration’s stated objective and exposes potential vulnerabilities in the country’s defense infrastructure.
In conclusion, the EPA’s proposal to ban methylene chloride, a key chemical used in the production of military gear, poses a threat to national security. It would result in increased reliance on foreign sources, particularly China, further compromising the independence and resilience of America’s defense apparatuses. The potential disruptions and compromises associated with a heavily dependent supply chain require careful consideration and proactive measures to safeguard the country’s strategic advantage and ability to respond effectively to national security threats. Balancing environmental concerns and national security imperatives is paramount, and policymakers must carefully weigh these factors when formulating regulations related to critical materials used in vital defense applications.
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