The Federal Register posted a “notice of requests for public comments” last month focused on ”the effects on the national security of imports of robotics and industrial machinery”. The survey has now closed, but let’s take a look at the document to understand what they are interested in seeing.
The survey is related to the US Code of Federal Regulations, Title 15, Subtitle B, Chapter VII, Subchapter A, Part 705, “EFFECT OF IMPORTED ARTICLES ON THE NATIONAL SECURITY”.
The purpose of these regulations are:
“These regulations set forth the procedures by which the Department shall commence and conduct an investigation to determine the effect on the national security of the imports of any article. Based on this investigation, the Secretary shall make a report and recommendation to the President for action or inaction regarding an adjustment of the imports of the article.”
Specifically, the survey was looking for information about the following:
(i) the current, projected, and optimal demand for robotics and industrial machinery, and their parts and components in the United States;
(ii) the extent to which domestic production of robotics and industrial machinery, and their parts and components can meet domestic demand;
(iii) the role of foreign supply chains, particularly of major exporters, in meeting United States demand for robotics and industrial machinery, and their parts and components;
(iv) the concentration of U.S. imports of robotics and industrial machinery, and their parts and components from a small number of suppliers or foreign nations and the associated risks;
(v) the impact of foreign government subsidies and predatory trade practices on the competitiveness of the robotics and industrial machinery, and their parts and components, in the United States;
(vi) the economic impact of artificially suppressed prices of robotics and industrial machinery, and their parts and components due to foreign unfair trade practices and state-sponsored overproduction;
(vii) the potential for export restrictions by foreign nations,
including the ability of foreign nations to weaponize their control over supplies of robotics and industrial machinery, and their parts and components;
(viii) the feasibility of increasing domestic capacity for robotics and industrial machinery, and their parts and components to reduce import reliance;
(ix) the impact of current trade policies on domestic production of robotics and industrial machinery, and their parts and components, and whether additional measures, including tariffs or quotas, are necessary to protect national security;
(x) the impact of the use or lack of use of robotics and industrial machinery on U.S. manufacturing employment;
(xi) the potential for foreign control or exploitation of the robotics and industrial machinery supply chain;
(xii) the ability of foreign persons to weaponize the capabilities or attributes of foreign-built robotics and industrial machinery, and their parts or components;
(xiii) the future role of robotics and industrial machinery in the production of items essential to national security or in activities related to national security; and
(xiv) any other relevant factors.
Does this include 3D printers? It’s not entirely clear. They write:
“For the purpose of this investigation “robotics and industrial machinery” includes, among other things, robots and programmable, computer-controlled mechanical systems. This equipment spans CNC machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. It also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding, and handling work pieces. Application-specific specialty metalworking equipment used to treat, form, or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery is also included.”
That paragraph does not specifically mention 3D printers or additive manufacturing, but indeed those machines are “computer controlled mechanical systems”. I think it could very well include 3D printers.
What does all this mean? It suggests that the US administration is interested in gathering information about non-US made manufacturing equipment, quite possibly including 3D printers. They specifically focus on the security aspects.
This is where things get interesting. Currently the vast majority of desktop 3D printers sold in the US are made elsewhere, and most of them involve some type of cloud management systems. Those cloud systems are almost always based outside of the US, typically in the origin country. In some cases, that country is China. Some could suggest there are security issues because of this.
It may be that this is one of the steps the US administration is taking towards future restrictions on imported 3D printers. To place restrictions, you need justifications, and to get justifications, you need information. This survey asked for that information.
There currently is no ban or restrictions on non-US 3D printers imported into the US, although there are tariffs that seem to change frequently. We don’t know if this survey and subsequent activities could lead to a ban on imported 3D printers — but we do know that such a ban has effectively taken place for DJI drone equipment.
Could imported 3D printers be next?
Via Federal Register
