Supply-Chain Restrictions for Defense Contractors Should Be Phased in, Not Rushed
Key Highlights
- Trump's July 20 executive order tightens up exemptions on defense contractors buying critical minerals from China, Russia, Iran and North Korea.
- Defense contractors have until January 1, 2027 to comply, a timeline that's not realistic to track lower-tier suppliers and find or create alternatives sourced in other countries.
- The U.S., for instance, does not have any capabilities for processing high-grade titanium for aerospace applications, and building that capacity will take years.
- Three adjustments would preserve the order's intent wihtout reducing its transition risk.
On July 20, President Donald Trump signed an executive order titled “Securing America's Defense Supply Chains and Ensuring Domestic Acquisition of Critical Materials.” It sharply restricts the waivers allowing defense contractors to buy critical minerals from China, Russia, Iran and North Korea.
White House adviser Peter Navarro summed up the new standard bluntly: “No more, ‘We tried nothing and we're out of options.’”
The deadline is unforgiving. Starting January 1, 2027, contractors seeking exemptions must prove an active, adequately funded effort to qualify domestic or allied alternatives.
The diagnosis behind the order is correct.
However, as a supply-chain researcher who has studied supply chains for over 30 years, I believe the prescription confuses a mandate with a capability.
By closing waiver loopholes before America rebuilds the industrial capacity those waivers compensate for, the order risks making U.S. defense production more fragile, not less, over the next several years. You cannot legislate a smelter into existence.
The Vulnerability Is Real
Two structural weaknesses justify the administration's alarm.
The first is supply-chain visibility. The Pentagon and its prime contractors have remarkably little insight into their own supply chains below Tier 2 or Tier 3. A Government Accountability Office review warned that the Defense Department cannot reliably identify where Chinese-sourced inputs enter its weapons programs. Research firm Govini found Chinese suppliers embedded in thousands of components across major U.S. military programs.
What the government cannot see, it cannot secure.
The second weakness runs even deeper. Over three decades, the United States lost not its mines but its metallurgy: the smelting, refining and separation stages that turn ore into aerospace-grade material.
Consider titanium, the backbone of modern airframes. The U.S. Geological Survey confirms that in 2025, America produced zero titanium sponge—the high-purity form of the metal—and now imports roughly 44,000 tons a year, mostly from Japan. The last major titanium sponge processing plant, in Henderson, Nevada, was idled in 2020, even after a Commerce Department Section 232 investigation concluded its loss would leave the country without surge capacity in a national emergency.
We saw the cliff coming. We drove off it anyway.
The story repeats with rare earths. The Mountain Pass mine in California produces concentrate, but China controls roughly 90% of global refining and processing capacity—the stage where oxides become usable metal. Beijing has spent the past two years wielding that chokehold deliberately, restricting exports of samarium, dysprosium and gallium whenever trade tensions flare.
The chokepoint is not the ore in the ground. It is the midstream processes.
The Waiver Cliff Arrives Before the Capacity Cliff
Now weigh the order's timeline against industrial reality.
The order gives the Secretary of War 180 days to require contractors at every tier to map their supply chains and produce indentured bills of materials tracing components back to raw-material origin. Barely five months later, the permissive waiver regime under 10 U.S.C. 4872 effectively ends.
Industrial physics does not move that fast.
A high-purity smelter for the cobalt and nickel superalloys in jet-engine hot sections requires billions in capital and almost a decade to build. The Kroll process for titanium sponge is a batch operation in sealed reactors at roughly 1,000 degrees Celsius; a single batch can take days, and scaling requires building entirely new reactor infrastructure. Achieving 99.9 percent purity for rare earth magnets demands hundreds of sequential solvent-extraction stages, and permitting a facility that generates toxic wastewater can consume years before ground is broken.
So defense primes—the major Tier 1 defense contractors—face a brutal interim choice. Pause production lines that depend on prohibited materials, or spend heavily on qualification programs just to keep temporary waivers alive.
Either path slows deliveries of munitions and aircraft when U.S. stockpiles are already stretched.
An order meant to reduce strategic exposure could deepen it for the next two to three years. That is precisely the window in which deterrence matters most.
What the Executive Order Mandate Misses
The secondary effects deserve more attention than they are getting.
Because using an “unreliable foreign supplier” now puts companies at risk of contract termination and fraud exposure, primes will push risk-management responsibilities including audit rights, liquidated damages and open-book requirements—onto Tier 2 and 3 suppliers who have long guarded their sourcing data as trade secrets. Many small and non-traditional suppliers—the very firms the order pledges to protect—will conclude that defense work is no longer worth the burden and exit.
The likely result: a more consolidated, more vertically integrated and considerably more expensive industrial base, as primes acquire upstream processors to control their own compliance data.
There is also a retaliation dynamic.
Every escalation of U.S. sourcing restrictions strengthens Beijing's incentive to tighten its own export controls while American alternatives remain years away.
China holds the scarce asset. Asymmetric dependence means asymmetric pain during the transition.
Sequencing, Not Slogans
None of this argues for complacency about Chinese leverage. It argues for matching ambition to industrial arithmetic.
Three adjustments would preserve the order's intent while reducing its transition risk.
First, phase in the waiver cliff by material category, tied to realistic capacity milestones rather than a single calendar date.
Second, make friendshoring the centerpiece, not the footnote: Japan, Australia, and Canada hold processing capabilities that can bridge the gap.
Third, pair the compliance stick with demand certainty, using long-term offtake agreements and price floors to make billion-dollar smelters bankable.
Supply chain resilience is built, not decreed.
The administration has correctly named America's most dangerous industrial dependency. Whether this order strengthens deterrence or temporarily undermines it depends on whether Washington now pursues capacity-building with the same urgency it has applied to prohibition.
About the Author

Christopher S. Tang
Distinguished Professor and Ca
Christopher Tang is a distinguished professor and the holder of the Carter Chair in Business Administration at the UCLA Anderson School of Management.
A scholar of global supply chain management, Tang’s interest in his field began in the private sector when he worked for IBM to solve internal production planning problems. Exposure to real-life industry projects motivated his academic research, where he developed teaching cases on microfinancing for the poor, mobile platforms for developing economies and new business models in the age of the Internet, among other topics.
Tang has been a consultant to numerous corporations, including Amazon, HP, IBM, Nestlé and Accenture. He has published six books and in addition to being a regular contributor to IndustryWeek, he has written for the Wall Street Journal, Barron’s, Financial Times, China Daily, Fortune, Bloomberg Law and The Guardian.
