April 29, 2021

WASHINGTON — In a new comment submission, global tech trade association ITI led a coalition of procurement-focused industry associations in expressing support for the Biden Administration’s efforts to ensure the security and resiliency of U.S. supply chains. The coalition urged the U.S. Department of Defense (DoD) to prioritize multilateralism and collaboration with U.S. allies when developing supply chain policies for strategic and critical materials. By doing so, DoD can avoid negative unintended consequences that could hamper the United States’ global economic competitiveness.

The comments were submitted by the Council of Defense and Space Industry Associations (CODSIA) in response to DoD’s request for comments on the Executive Order, America’s Supply Chains.

“We strongly urge DoD officials to advocate for, and help develop, policies regarding strategic and critical materials supply chains that emphasize multilateralism and collaboration with U.S. allies and partners, and that leverage pre-existing standards and best practices,” the group wrote. “We have strong concerns that without due consideration and careful policy development, there could be negative unintended consequences that add significant compliance costs and resource burdens on companies; disrupting or dismantling legacy supply chains in order to achieve acceptable supply chain security may result in considerable up-front and sustainment costs, and U.S. government policy development in this area must account for those potential effects.”

In the comments, the group of associations specifically called on DoD to:

  • Work with allied/partner economies (especially those in the Asia-Pacific region like South Korea, Taiwan, and Japan) to strengthen diplomatic ties, reduce market access barriers, and diversify supply chains.

  • Leverage existing standards and best practices that promote responsible behavior for considerations like environmental impact, forced labor, and chemical management.

  • Prioritize building and maintaining the U.S. domestic workforce by investing in STEM education and updating the H-1B and H-2B visa programs to allow companies to address their labor shortages.

  • Expand existing diplomatic efforts and maintain U.S. leadership on sourcing transparency and the need to cease human rights abuses associated with the strategic and critical materials supply chain.

  • Incentivize industry participation in responsible sourcing initiatives as well as maintain a voluntary reporting mechanism for sharing traceability, environmental, and labor information with the federal government.

  • Facilitate long term R&D investments to reimagine a more sustainable and secure critical materials supply chain by evaluating current stockpiles of U.S. critical materials, investing in supply chain illumination, and leveraging cooperative programs.

You can read the full comments here.

Public Policy Tags: Public Sector