The Bureau of Industry and Security (BIS) is currently engaged in an investigation regarding the effect that a reliance on foreign imports of “critical minerals” and their derivative products (see definition below) has on the national security of the United States. This investigation is being undertaken to determine if any trade actions (such as restrictions on imports, additional tariffs, or promotion of domestic production) should be taken to protect the nation’s security interests.

NSSF is currently considering submitting a comment to BIS on behalf of our members, to illustrate what effect any trade restrictions or additional tariffs on critical minerals might have on our industry. Accordingly, NSSF is interested to learn the following from members:

1. Do you import critical minerals or their derivative products for further manufacture or resale?
2. If so, which critical minerals do you import, and at approximately what annual volume?
3. Which foreign countries do you import these articles from?
4. For manufacturers – what categories of products are these critical minerals or derivative products incorporated into?
5. For importers and retailers – what types of derivative products do you import?
6. If additional tariffs or restrictions on importation were imposed on these articles, what effect would that have on your business? (For example, would your manufacturing costs be greatly impacted? Would increased costs or restrictions on available imports result in decreased sales? Or would such action spur beneficial growth in alternative supply chains?)
7. Do you have any suggestions on actions that the government might take to reduce dependence on foreign critical minerals without negatively impacting industry?

The deadline for public comments on this matter is May 16, 2025. We ask that members direct any input or responses to NSSF’s Assistant General Counsel, Tim Lachance, no later than May 12, 2025 at tlachance@nssf.org.

*Critical minerals are defined by the USGS, and a full list can be found here. Derivative products of critical minerals for the purposes of this action include final products or components which incorporate critical minerals in some way. Critical minerals that may be of particular import to the firearms and ammunition industry include the following: aluminum, bismuth, chromium, erbium, germanium, magnesium, nickel, tin, titanium, tungsten, and zinc.