Issue Briefs
TNT One Pager
Our Asks
- Congress should work in cooperation with the U.S. Department of Defense and the Biden Administration to address the current TNT scarcity and identify ways to reduce barriers to the importation of TNT into the United States. While IME supports and understands the needs of the defense industry, the needs of the commercial explosives industry must not be displaced, and contracts and orders should not be interrupted. This will help ensure vital infrastructure projects and critical mineral development are completed in a timely and cost-effective manner.
- In order to maintain a strong domestic commercial explosives manufacturing industry, Congress should act to ensure that the commercial explosives industry is able to domestically source TNT.
- IME also supports federal funding and incentives for research and development of new, cost -effective, and sustainable high explosives which provide the commercial explosives industry with new tools to meet evolving customer needs and minimize environmental impacts.
What is TNT?
TNT, or 2, 4, 6-trinitrotoluene, is a high explosive. The yellow, odorless substance is solid at room temperature and does not occur in nature. TNT is manufactured by combining toluene with nitric and sulfuric acids.
How is TNT Used?
TNT is widely used by both the commercial explosives industry and the U.S. military. Due to its stability and shelf life, TNT is desirable for numerous applications. Unlike some high explosives, TNT is relatively insensitive and is not prone to detonation without shock (from another explosive or detonator), physical impact, static electricity, or extreme heat.
How does the military use TNT?
TNT is the Army’s most widely used military explosive. TNT is used by the defense industry for various applications, including the manufacture of artillery shells, grenades, and airborne bombs.
How does the commercial explosives industry use TNT?
TNT is an essential ingredient in the manufacturing of commercial explosives products like cast boosters, commonly used in the mining, quarrying, and construction industries. Thanks to innovation in the safety of our products, today’s relatively insensitive blasting agents require the high output power of cast boosters to detonate.
Where does the U.S. Source TNT From?
Since 1986, TNT is no longer manufactured in the United States, leaving our nation highly vulnerable to shortages and solely dependent on foreign sources. The U.S. imports TNT from Poland, Turkey, South Korea, Australia, and India. Other major producers of TNT include China and Russia, however due to current geopolitical conflicts, the U.S. does not currently import TNT from either of these countries.
Why Did We Stop Producing TNT in the U.S.?
TNT was manufactured in the U.S. until 1986, when the Radford Army Ammunition Plant located in Virginia, ceased manufacturing the product because “environmental regulations became increasingly more stringent and costly to implement.”
Environmental Concerns
Production of TNT creates wastewater known as “red water” or “pink water” which, if not properly controlled, can be absorbed into soil leading to adverse health and environmental effects. These potential environmental effects of TNT can be remediated through vacuum distillation, layer melt crystallization, and other proven control technologies.
Why Do We Have a TNT Shortage?
Current geopolitical conflicts have made it extremely difficult to source TNT from many of the countries the U.S. previously relied upon. Both the Army and the commercial explosives industry are experiencing difficulty securing the material. The current shortages compromise the U.S. defense sector and puts in limbo the many infrastructure priorities and projects created by the Bipartisan Infrastructure Law and the CHIPS and Science Act. The commercial explosives industry may not have the necessary tools to complete these projects without TNT and where TNT can be sourced, there will almost certainly be increased costs, leading to higher-cost projects.
Can we produce TNT Domestically?
In September 2023, the Army published a Sources Sought for the Construction and Operation of a TNT facility in the U.S. The proposed facility would produce approximately five million pounds of TNT per year. The construction of the plant was funded through the Ukraine Supplemental in 2024. Currently, the Army is reviewing applications in response to the Sources Sought. However, the construction of this plant is not an immediate solution to the TNT shortage.
Tariff One Pager
Download IME's Tariff One Pager
The commercial explosives industry operates within a highly integrated global supply chain, relying on critical inputs sourced both internationally and domestically. While some materials can be produced within the U.S., domestic supply is often limited and, in some cases, non-existent. Competition from the defense sector further constrains the availability of some materials.
Tariffs on key imports negatively impact not only the explosives industry but also the critical industries that rely on it - including the $121.7 billion mining and critical minerals industry, the $2.2 trillion quarrying and construction industry, and the $818.2 billion energy industry. Higher input costs due to tariffs raise the prices on goods and services throughout the economy, impacting key Administration priorities and driving up expenses for American businesses – costs that eventually fall on consumers.
Commercial Explosives Key Inputs
High Explosives (HMX, RDX, HNS, PETN, TNT)
The U.S. remains heavily dependent on foreign sources for high explosives such as HMX, RDX, HNS, and TNT—core ingredients in many commercial explosive products.
- HMX, HNS, and RDX, classified under Chapter 36 of the Harmonized Tariff Schedule, are imported primarily from Norway, Sweden, Poland, Germany, China, South Korea and other nations.
- TNT is not presently produced in the U.S. Though a domestic production facility is planned, current sources of TNT include Turkey, China, Vietnam, Australia and India; due to geopolitical tensions, traditional sources like Poland and Ukraine are no longer reliable.
Ammonium Nitrate and Ammonia
Over 90% of commercial explosives consumed in the U.S. are ammonium nitrate (AN) based due to AN’s safety and relatively stable domestic supply. While the U.S. produces AN, domestic production is not sufficient to meet the overall demand. Importing AN helps the U.S. stabilize the supply chain and manage price fluctuations in the domestic market. AN is imported from Canada, due in large part to transportation logistics, as well as Russia, Vietnam, China, the Netherlands, Mexico and other nations.
Anhydrous ammonia is the basic building block for all nitrogen products. Ammonia is currently produced at 35 plants in 16 states.[1] While U.S. production capacity for ammonia is strong, we import product from Canada, again, based on logistics, as well as Trinidad and Tobago, Algeria, Indonesia, Belgium and other countries.
Detonating Cords, Caps, and Fuses
Detonating cords, detonators, and safety fuses are vital components in explosive systems.
- These are sourced both domestically and internationally from Mexico, Canada, Brazil and other countries.
- Despite some domestic manufacturing, imports remain necessary to meet demand.
Steel and Aluminum
The commercial explosives industry is reliant on a specific steel alloy necessary for the manufacture of perforating guns used in the oil and gas industry. The steel needed for the manufacture of this important tool for oil and gas extraction, is primarily sourced from China and is not produced in the US.
IME’s Asks of Congress:
To strengthen domestic industries and maintain cost-effective operations, the following inputs should be exempt from current and future tariffs:
- High explosives: HMX, HNS, RDX and TNT
- Key chemical components: Ammonia, Ammonium Nitrate
- Essential raw materials: Specialized Steel Alloy
Exempting these materials from tariffs will stabilize supply chains, maintain competitiveness, and support core industries that drive the American economy. Alternatively, increasing tariffs that impact the explosives industry will disrupt well established supply chains. This could lead to more cautious spending and delayed investments in U.S. based mining companies.
[1] https://pubs.usgs.gov/periodicals/mcs2022/mcs2022-nitrogen.pdf
Supply Chain One Pager
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Background
A strong domestic commercial explosives industry is essential to the U.S. economy. Each year, the U.S. commercial explosives industry contributes over $19.1 billion annually to the economy and supports more than 60,000 jobs. Our products are fundamental to key sectors including the $121.7 billion mining industry, the $2.2 trillion construction sector, and the $812.2 billion energy market. To ensure consistent production, commercial explosives manufacturers depend on stable, domestic supplies of crucial raw materials.
High Explosives
High explosives—HMX, RDX, PETN, HNS and TNT—are crucial to both the commercial explosives sector and the U.S. defense industry. However, domestic supply is severely limited.
- HMX and RDX are only produced at the Holston Army Ammunition Plant (Kingsport, Tennessee), a government-owned, contractor-operated facility focused on Department of Defense needs. The commercial sector can only access surplus production, which has been challenging for the past two years.
- HNS is produced at the Naval Surface Warfare Center, Indian Head Division (Charles County, MD), run by the US Navy. The commercial sector is unable to source from this facility and must import its supply of HNS.
- TNT is not currently manufactured in the U.S. Domestic manufacturers are entirely dependent on imports from countries such as Turkey, China, and India. Due to geopolitical tensions, traditional sources like Poland and Ukraine are no longer reliable. A U.S.-based TNT plant is planned but is not expected to be operational for three years.
- PETN is produced at three facilities in the U.S., providing relatively stable access.
Applications of High Explosives
- HMX: Used in detonating cords and shaped charges for oil and gas production and demolition.
- RDX: Similar to HMX, used in shaped charges and detonating cords across various industrial sectors.
- HNS: Like HMX and RDX, HNS is used in shaped charges and detonating cords in the oil and gas sectors. HNS is used in higher temperature applications.
- TNT: Valued for stability and shelf life, TNT is a key component of cast boosters used in mining and quarrying.
- PETN: Sensitive but stable under normal conditions, PETN is used in detonating cords, detonators, and cast boosters.
Ammonium Nitrate (AN)
Over 90% of commercial explosives in the U.S. are AN-based, due to its safety, stability, and availability. It is used in two forms:
- Ammonium Nitrate Solution (ANS) – liquid form.
- Technical Grade Ammonium Nitrate (TGAN) – solid bead form, known as "prill."
AN is inert on its own but becomes explosive when combined with fuel. Its stability makes it ideal for high-volume industrial use. Any new regulations must be grounded in science to avoid disrupting the current stable supply.
Uses of Ammonium Nitrate
- AN is the base for products like ANFO, emulsions, water gels, and slurries—commonly used in mining, construction, and quarrying.
Ask to Congress
To maintain a secure and competitive domestic commercial explosives industry, Congress should:
- Support policies that promote domestic sourcing and production of essential materials, including HMX, RDX, HNS and TNT.
- Ensure that any legislation or regulation affecting ammonium nitrate is science-based and does not hinder availability of this important product.
Modernizing ATF Regulations for Commercial Explosives
Download IME's ATF Modernization Fact Sheet
The commercial explosives industry is among the most highly regulated sectors in the United States. The Institute of Makers of Explosives (IME) recognizes the critical importance of regulation when working with such powerful materials. IME supports common-sense regulations that are rooted in sound science, data, and that reflect our industry’s best practices.
Safety regulations have been central to IME’s mission since its founding over a century ago. Since then, IME has developed and published comprehensive safety standards through its Safety Library Publications (SLPs), which provide best practices for the manufacture, storage, transportation, distribution and use of commercial explosives. These 19 publications have been widely adopted and incorporated into numerous federal, state, and local regulations. Since 1960, IME’s SLPs have been cited in federal regulations 42 times.
Background
It has been more than two decades since the last comprehensive review of ATF’s regulations for commercial explosives. As a result, current rules and definitions are increasingly misaligned with modern industry practices and today’s business environment. Some regulations have become unnecessarily burdensome without providing meaningful improvements to safety or security.
The Role of the ATF
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) serves as the primary federal regulator of the commercial explosives industry. IME has worked collaboratively with ATF to propose regulatory updates and has found a cooperative partner in the agency.
IME’s top three regulatory modernization priorities include:
- Timely background checks and clearances for workers
- Modernization of recordkeeping requirements
- Adoption of the IME Safety Analysis for Risk (IMESAFR)
- Timely Background Checks and Clearances
All personnel who handle commercial explosives must undergo ATF background checks. In some cases, these checks can take up to six months, disrupting operations in an already tight labor market.
IME Recommends:
- Expediting background checks through the FBI’s National Instant Criminal Background Check System (NICS)
- Making background clearance records transferable between employers
- Creating a timely appeal or relief process for long-standing employees flagged during renewal of their Federal Explosives License/Permit (FEL/FEP)
- Allowing subcontractors, temporary workers, and interns to be vetted as an Employee Possessor under a company’s federal explosives license
- Modernize Recordkeeping Requirements
Accurate inventory tracking is vital for ensuring the safety and security of commercial explosives. However, current regulations need modernization to support more efficient recordkeeping.
IME Recommends:
- Update regulations to formally allow electronic recordkeeping, which ATF currently permits only on a case-by-case basis
- Permit a unified set of records for companies, rather than requiring separate records for import, export, distribution, and use—improving both efficiency and security
- Adopt IMESAFR as a Risk Management Tool
The American Table of Distances (ATD) - originally developed by IME more than a century ago - provides safety guidelines for storing commercial explosives. With advancements in explosives and industry practices, IME developed the IME Safety Analysis for Risk (IMESAFR) in partnership with APT Research in 2004. This quantitative risk assessment tool models potential hazards to workers and the public from explosive facilities and operations.
IME Recommends:
- ATF should formally adopt IMESAFR as a recognized tool for businesses to assess and mitigate risk while enhancing public and workforce safety.
IME’s Asks for Congress:
- Provide dedicated funding to complete the development of electronic forms (e-forms) for the Federal Explosives License/Permit (FEL/FEP), Responsible Person Questionnaire (RPQ), and Employee Possessor Questionnaire (EPQ). Transitioning to e-forms will reduce processing times, reduce government costs, and provide greater certainty for both employees and employers. Increased certainly will lead to better outcomes for not only the commercial explosives industry but the sectors it supports including the mining/quarrying, construction/infrastructure and energy sectors.
- Encourage ATF to modernize its regulatory framework - specifically the Orange Book - to reflect today’s technology and business practices, improving both compliance and administrative efficiency.
DHS/ATF: Duplicative Regulation of Commercial Explosives
Download IME's CFATS One Pager
Background:
The Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program aims to secure high-risk chemical facilities against terrorism by requiring them to assess and report security risks and vulnerabilities, develop security plans, and comply with security measures. However, these requirements are duplicative of existing commercial explosives regulations enforced by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), whose mission is, “preventing terrorism, reducing violent crime involving the criminal misuse of explosives, and protecting the public by enforcing laws and regulations”.
Facts:
- Thefts of explosives have seen no significant reduction following CFATS implementation in 2007.
- A 2021 GAO report, entitled Chemical Security: Overlapping Programs Could Better Collaborate to Share Information and Identify Potential Security Gaps found the majority of CFATS requirements for commercial explosives directly overlap with pre-existing ATF regulations.
- In a 2021 Advanced Notice of Proposed Rulemaking (ANPRM) entitled Removal of Certain Explosive Chemicals From the Chemical Facility Anti-Terrorism Standards DHS indicated “we believe that these regulations may be unnecessarily burdensome for facilities that are already subject to security regulations for the same chemicals by another Federal agency, ATF.” Unfortunately, this ANPRM has yet to be formalized into a rulemaking.
- While developing it’s Risk Management Plan regulations, the EPA issued a final rule removing Division 1.1 explosives from its list of regulated substances for accidental release prevention concluding that “. . . current [ATF and other] regulations and current and contemplated industry practices promote safety and accident prevention in storage, handling, transportation, and use of explosives, making them adequate for EPA's purposes.”
Our Position:
The commercial explosives industry has been effectively regulated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) since implementation of the Safe Explosives Act of 1970. All available government data shows that there has been no significant reduction in thefts of commercial explosives since implementation of the CFATS program.
Our Ask:
Commercial explosives should be removed from the CFATS program’s Appendix A: Chemicals of Interest list by amending the legislation to include the following language “The Secretary may not designate any explosive material subject to regulation by the Department of Justice under chapter 40 of title 18, United States Code, or by the Bureau of Alcohol, Tobacco, Firearms, and Explosives under part 555 of title 27, Code of Federal Regulations, as a chemical of interest under Appendix A to part 27 of title 6, Code of Federal Regulations, or any successor thereto”.
