Comments on the draft harmonized system code list of critical supply chains

Marta Wosińska and Rena Conti submitted comments to the Commerce Department’s request for feedback on their list of critical supply chains. The Commerce Department indicates they will use the resulting list of critical goods and materials to facilitate ongoing targeted analysis of trade data and the evaluation of policies to strengthen these supply chains.

In their comment letter, Wosińska and Conti suggest ways to expand the Commerce list beyond the existing FDA essential medicines list. They argue that an expansion is needed because the criteria used to formulate the FDA list differ from the goals of Executive Order 14017 that followed.

The existing Essential Medicines, Medical Countermeasures and Critical Inputs list was created to develop a list of drugs needed during demand shocks such as “outbreaks of emerging infectious diseases and chemical, biological, radiological, and nuclear (CBRN) threats.” In turn, the executive order that followed expanded the criteria to account for supply disruptions due to “extreme weather events, terrorist attacks, geopolitical and economic competition, and other conditions.”

Read the full comment letter here.

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