AHA Responds to Commerce Department Investigation of Critical Minerals

May 16, 2025

Stephen Astle
Director, Defense Industrial Base Division
Office of Strategic Industries and Economic Security
U.S. Department of Commerce
1401 Constitution Ave, NW
Washington, DC 20230

RE: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (XRIN 0694-XC124), April 25, 2025

Dear Director Astle: 

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Department of Commerce’s request for public comment on its Section 232 national security investigation on processed critical minerals and derivative products. The investigation could form the basis for future tariffs or other trade restrictions on these products.

Critical minerals — including certain rare earth materials — are essential to the manufacture and operation of many medical devices that hospitals and health systems use to diagnose and treat patients every day. For example, magnetic resonance imaging (MRI), computerized tomography (CT), positron emission tomography (PET), radiopharmaceuticals and radiation therapy equipment all require the ready availability of critical minerals to function as intended. A substantial proportion of the critical minerals used in medical devices and therapies are either extracted or processed internationally, even when the device or therapy is manufactured in the U.S.

The AHA shares the administration’s long-term goal of securing reliable sources for critical minerals, including by strengthening domestic capabilities for mining and processing such minerals where possible. At the same time, achieving this goal will require a significant amount of time, given the logistical complexity and resources involved in shifting the supply chain for critical minerals. In the short term, we are concerned that tariffs on critical minerals used in health care — and any retaliatory action from the countries on which tariffs are imposed — could inadvertently disrupt the availability of critical diagnostic and treatment tools on which effective patient care relies. Tariffs and retaliatory actions from other nations also could significantly raise hospital costs.

The AHA urges the administration to consider tariff exceptions for critical minerals and derivative products that are used for medical purposes. These exceptions could be coupled with continued engagement with multiple stakeholders —hospitals and health systems, device and drug manufacturers, mining and mineral processors and others — to explore approaches to making the supply chain for critical minerals used in medical devices and therapies more resilient and, when feasible, less dependent on international sources.

Multiple minerals on the critical minerals list are essential to aiding diagnosis and delivering treatments, and are heavily dependent on international sources, especially China. For diagnostic imaging, gadolinium is a rare earth material used in contrast fluid, which improve MRI precision. Contrast fluid can help identify vascular aneurysms and blockages, spinal cord injuries and brain tumors. Lutetium, another rare earth material, is used to produce very high-resolution PET/CT scans that help physicians determine how aggressive a tumor is and inform treatment plans. The U.S. is 80% reliant on international sources for rare earth materials.ⁱ Lutetium along with yttrium are also critical components of radiopharmaceuticals that are used to help shrink certain kinds of tumors. All of the yttrium used in the U.S. is imported, with 93% of it coming from China.ⁱⁱ Tungsten is also an essential component used to make certain linear accelerators that deliver radiation therapy treatment, with over half of the U.S. supply coming from China.ⁱⁱⁱ Tariffs on these and other critical minerals used in health care could lead to disruptions in the availability of these critical patient care tools.

Lastly, the AHA is concerned about the potential for tariffs to raise the costs of delivering care to hospitals and health systems. Tariffs on critical minerals could have a particularly significant impact on complex medical devices that are higher cost and lower volume, in part due to requiring specialized parts and customization to meet the needs of health care providers. A recent survey found that 82% of health care experts expect tariff-related expenses to raise hospital costs by at least 15%, and 90% of supply chain professionals expect procurement disruptions.^iv Given that hospital payments are set by government and private payer contracts, the costs would be borne by hospitals directly. As underscored by the AHA’s recent Cost of Caring report, such cost increases could further compound the broader financial headwinds challenging hospitals’ ability to provide care to patients and communities.^v

Thank you for the opportunity to provide feedback on this notice. We welcome the opportunity to discuss with your team how to preserve access to medical devices and technologies that depend on critical minerals and ensure that hospitals can continue delivering safe and effective care. Please contact me if you have questions at ademehin@aha.org.

Sincerely,

/s/

Akinluwa (Akin) A. Demehin
Vice President
Quality and Safety Policy
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