Ensuring National Security and Economic Resilience Through Section 232 Actions on Processed Critical Minerals and Derivative Products

4/15/2025

Action Summary

  • National Security Rationale: Emphasizes that processed critical minerals and their derivative products are essential for both economic stability and national defense, underpinning key industries such as manufacturing, transportation, energy, and defense systems.
  • Supply Chain Vulnerabilities: Highlights significant risks due to U.S. reliance on a limited number of foreign suppliers, exposing the nation to geopolitical tensions, price manipulation, and supply chain disruptions.
  • Key Definitions:
    • Critical minerals: As listed by the USGS and including uranium.
    • Rare earth elements: The 17 elements defined by the DOE, with potential for additional elements as determined by USGS or DOE.
    • Processed critical minerals: Minerals that have been processed from extracted ore into metals, powders, or master alloys.
    • Derivative products: Goods incorporating processed critical minerals, from semi-finished products to final consumer goods.
  • Section 232 Investigation:
    • The Secretary of Commerce is directed to initiate an investigation under Section 232 to assess the national security impact of importing these materials and products.
    • Investigation components include:
      • Identifying import volumes and sources.
      • Assessing risks related to geopolitical issues, pricing strategies, and market distortions by foreign producers.
      • Evaluating domestic production capabilities and the demand for processed critical minerals.
      • Quantifying the economic value of current import levels by source and value.
    • Reports and Recommendations:
      • A draft interim report is due within 90 days for review by key officials.
      • Final report and recommendations, including potential tariffs, safeguards, and domestic production incentives, to be submitted within 180 days.
  • Implementation and Legal Provisions:
    • The order maintains existing executive department authorities and budgetary functions.
    • It is subject to applicable law and available appropriations and does not create enforceable rights against the government.

Risks & Considerations

  • The Executive Order highlights the vulnerabilities in the supply chain for processed critical minerals, which are essential for national security and economic resilience. This could lead to increased scrutiny and potential regulatory changes affecting industries reliant on these materials.
  • Vanderbilt University may face challenges in research and development areas that depend on critical minerals, particularly in fields like advanced manufacturing, energy, and defense technologies.
  • The potential imposition of tariffs and import restrictions could increase costs for research projects and collaborations that rely on imported processed critical minerals and derivative products.
  • There is a risk of disruption in the availability of critical minerals, which could impact ongoing and future research initiatives at Vanderbilt, particularly those involving advanced computing, telecommunications, and energy infrastructure.
  • The focus on incentivizing domestic production and processing of critical minerals may present opportunities for Vanderbilt to engage in research partnerships and initiatives aimed at developing sustainable and resilient supply chains.

Impacted Programs

  • School of Engineering at Vanderbilt may need to adapt its research focus to align with national priorities on critical minerals and their applications in defense and technology sectors.
  • Vanderbilt Institute for Energy and Environment could play a significant role in exploring sustainable practices for critical mineral extraction and processing, potentially securing federal funding for such initiatives.
  • The Office of Federal Relations may need to increase its advocacy efforts to ensure that Vanderbilt’s interests are represented in policy discussions related to critical minerals and national security.
  • Vanderbilt’s partnerships with industries reliant on critical minerals may need to be reevaluated to ensure alignment with new regulatory and market conditions.

Financial Impact

  • The Executive Order could lead to increased costs for research projects that depend on imported critical minerals, potentially affecting budget allocations and funding strategies at Vanderbilt.
  • Opportunities may arise for Vanderbilt to secure federal grants and funding for research focused on developing domestic capabilities in critical mineral processing and derivative product manufacturing.
  • Changes in the supply chain dynamics for critical minerals could impact the financial viability of certain research initiatives, necessitating adjustments in project planning and resource allocation.
  • Vanderbilt may need to explore alternative funding sources and partnerships to mitigate the financial risks associated with potential supply chain disruptions and increased regulatory requirements.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of programs.)

Key Actions

  • Vanderbilt’s School of Engineering should explore research opportunities in the development of technologies that utilize processed critical minerals. By focusing on innovation in areas such as advanced manufacturing and telecommunications, the school can position itself as a leader in addressing supply chain vulnerabilities.
  • The Office of Federal Relations should engage with policymakers to advocate for policies that support domestic production and processing of critical minerals. This engagement can help ensure that Vanderbilt’s interests are represented in national discussions on economic resilience and national security.
  • Vanderbilt’s Center for Technology Transfer and Commercialization should identify potential partnerships with industry leaders in the critical minerals sector. By fostering collaborations, the center can facilitate the commercialization of research and technologies developed at Vanderbilt.
  • The Department of Political Science should conduct analyses on the geopolitical implications of critical mineral supply chain dependencies. This research can provide valuable insights into the broader impacts of these dependencies on national security and economic stability.
  • Vanderbilt’s Environmental and Sustainability Studies Program should investigate sustainable practices in the extraction and processing of critical minerals. By promoting environmentally responsible methods, the program can contribute to the development of a more sustainable supply chain.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s Research Centers to secure funding for projects focused on enhancing the resilience of supply chains for critical minerals. By aligning research initiatives with national priorities, Vanderbilt can attract federal and private sector support.
  • Vanderbilt can capitalize on the increased focus on critical minerals by developing educational programs that prepare students for careers in industries reliant on these resources. This could include new courses and degree programs in materials science, engineering, and policy studies.
  • The emphasis on domestic production and processing offers an opportunity for Vanderbilt’s Innovation and Entrepreneurship Center to support startups and ventures in the critical minerals sector. By providing resources and mentorship, the center can help drive innovation and economic growth.
  • By engaging with the broader scientific and policy community, Vanderbilt can position itself as a thought leader in the national conversation on critical minerals. Hosting conferences, workshops, and public forums on the implications of supply chain vulnerabilities can further establish Vanderbilt as a hub for innovative thought and practice.

Relevance Score: 4 (The order presents the potential for major process changes required for Vanderbilt’s programs due to the focus on critical minerals and supply chain resilience.)

Average Relevance Score: 4.2

Timeline for Implementation

  • Draft Interim Report: Submit within 90 days of April 15, 2025.
  • Comments on Interim Report: Provide within 15 days after the interim report is submitted.
  • Final Report: Submit within 180 days of the investigation’s commencement.

Relevance Score: 5

Impacted Government Organizations

  • Department of Commerce: Charged with initiating the section 232 investigation and compiling both interim and final reports assessing national security risks from processed critical minerals and derivative products.
  • Department of the Treasury: Receives the draft interim report for internal review, playing a role in evaluating economic implications related to national security and trade.
  • Department of Defense: Provided with the interim report to assess potential impacts on military infrastructure and defense preparedness.
  • Office of the United States Trade Representative (USTR): Included in the internal review process to evaluate trade and import dependencies that affect national security.
  • Office of Management and Budget (OMB): Although its core functions remain unaffected, its role in budgetary oversight is mentioned to ensure the order is implemented within appropriations.
  • United States Geological Survey (USGS): Referenced for its “Critical Minerals List,” which supports the definitions and analytical framework used in the investigation.
  • Department of Energy (DOE): Cited in relation to rare earth element identification and analyses, contributing to the technical foundation of the order.

Relevance Score: 3 (Six to ten Federal Agencies are impacted by the order.)

Responsible Officials

  • Secretary of Commerce – Tasked with initiating and conducting the section 232 investigation on processed critical minerals and their derivative products, and reporting findings to the President.
  • Secretary of the Treasury – Receives the draft interim report for internal review and comment.
  • Secretary of Defense – Reviews the draft interim report and provides comments regarding national security implications.
  • United States Trade Representative – Involved in reviewing the draft interim report to assess trade-related impacts.
  • Assistant to the President for Economic Policy – Reviews the draft interim report, contributing economic policy insights.
  • Senior Counselor to the President for Trade and Manufacturing – Provides feedback on the draft interim report addressing trade and manufacturing concerns.

Relevance Score: 5 (Directives affect high-level Cabinet officials and White House advisors, ensuring comprehensive oversight on national security and economic policy matters).