by Oscar Diez, Project Manager, ConsultPet Engineering & Solutions, Brazil
On December 10, 2025, Republican lawmakers sent a letter to President Donald Trump expressing concern over the country’s heavy dependence on China for essential vitamins and amino acids used in human nutrition, animal feed and petfood. Approximately 78 percent of US vitamin imports come directly from China. For some products, such as biotin, global production is entirely concentrated there. These nutrients are fundamental to the health, growth and productivity of farm animals, pets and humans. The letter states that such dependence creates a food and national security risk, as a disruption in Chinese supply could affect availability and costs.
The importance of this issue does not lie solely in reading the letter, but in understanding why it was necessary for such a letter to exist. This requires going far beyond headlines or superficial analyses. US dependence on China for vitamins and microingredients is not a recent, accidental or simple phenomenon. It is the result of industrial decisions, trade policies, regulatory gaps and global strategies accumulated over decades.
For this reason, this article seeks to help the reader understand why the US government was compelled to elevate this issue directly to the President, why the security of the vitamin supply chain is now a national strategic matter and why any serious attempt at a solution requires deep, technical and well-founded analysis.
What the letter reveals
The letter presents explicit facts about extreme dependence on products originating from China. It states that vitamins, microingredients and other essential nutrients used for both human and animal consumption represent a risk to US national food security. Nine external sources support the argument, highlighting: China’s absolute dominance in vitamin production; vulnerabilities in the North American animal supply chain; dependence on China for micronutrients used in infant formulas; iFEEDER reports on impacts to food security; dependencies across the pharmaceutical supply chain; China’s control over strategic materials and the concentration of vitamin C production in China.
The letter does not mention accumulated lack of industrial capacity, nor loss of productive know-how, nor historical outsourcing of risk. The letter itself is a real symptom, not a cause.
National priority and coordination in China
China elevated biomanufacturing (bioprocesses and industrial fermentation) to the level of a national strategic priority, treating it as part of its critical industrial base rather than as just another market sector. It officially defined the sector as strategic, incorporating industrial biotechnology, microbial fermentation, vitamins, amino acids and enzymes into its Five-Year Plans, with clear targets for self-sufficiency, installed capacity and export leadership.
China also coordinated the entire state under a single direction, enabling ministries, provincial governments, state-owned banks and regulators to act in an aligned manner, preventing contradictory policies across industry, trade, energy and environmental domains. Another key strength was the use of industrial catalogues to direct investment: only activities listed as ‘encouraged’ received financing, tax incentives, industrial land and priority energy access, thereby steering private capital toward products defined as critical.
China ensured continuity beyond political cycles by anchoring the strategy in national planning and multi-year budgets. The strategy did not depend on temporary decrees, thus guaranteeing stability for long-term investments. Finally, vitamins and amino acids were treated as strategic infrastructure, not as simple commodities, but as essential inputs for human and animal nutrition, pharmaceuticals and food security, thereby justifying direct state intervention.
By contrast, the United States acts in a reactive and fragmented manner because its institutional framework prioritises market efficiency and short-term returns, without treating vitamins, amino acids and microingredients as strategic infrastructure. The lack of binding interagency coordination, regulatory uncertainty and dependence on political cycles discourage long-term, high-CAPEX industrial investments.
In summary, the United States cannot replicate the Chinese model; its realistic objective is to institutionalise biomanufacturing as a national priority and reduce structural dependence from 70–80 percent to manageable levels of 30–40 percent, rather than eliminate it entirely.
Global vision and creation of empire
China’s leadership in the global production of amino acids, vitamins and microingredients is the result of a long-term, state-led industrial strategy sustained for more than two decades. These inputs were identified early on as strategic sectors due to their cross-cutting impact on human nutrition, animal nutrition, pharmaceuticals and biotechnology.
China developed a fully integrated industrial ecosystem, from raw materials and chemical intermediates to fermentation, purification and final formulation (premixes). This vertical integration reduced external dependencies, optimised costs and enabled greater control over the supply chain. The model was reinforced through economies of scale supported by active industrial policies: energy subsidies, long-term state financing and tolerance for low margins over many years, with the objective of consolidating global leadership and displacing competitors.
In parallel, China accelerated the accumulation of technical knowledge through joint ventures, reverse engineering, and the large-scale training of chemical engineers and biotechnologists, achieving not only the replication of existing technologies but also their adaptation and efficient scaling. The result is that China does not merely dominate production; it dominates the entire ecosystem, which explains the structural dependence of multiple countries and the difficulty of reversing it in the short term.
The United States operates under an institutional model that prioritises market efficiency and short-term returns, without sector-specific industrial planning. These inputs have not been formally treated as strategic infrastructure, resulting in reactive and fragmented action. In other words, the US optimises immediate economic efficiency, while China optimises long-term strategic resilience.
Technical lessons from the Chinese model
Over the past three decades, China has consolidated structural dominance over the global production of amino acids, vitamins and microingredients essential to the animal nutrition, pharmaceutical and food industries. This dominance is the result of coherent technical, regulatory, industrial and financial decisions.
Technological base in China vs the USA
Modern amino acid production in China relies almost exclusively on large-scale microbial fermentation, replacing traditional chemical routes due to higher production yields, lower environmental impact and superior industrial scalability. The most representative products include L-lysine, L-threonine and L-tryptophan, produced using genetically optimised microbial strains.
US universities, research centres and companies possess knowledge in microbial fermentation that is equal to or superior to that of China. However, this knowledge was not translated into large-scale industrial capacity, particularly for commodity products such as L-lysine or L-threonine. In the United States, fermentation remained concentrated in pharmaceuticals, bioethanol, specialty enzymes and high-value bioproducts, while China industrialised high-volume, low-margin fermentation.
Industrial process flow
The standard amino acid production process comprises substrate preparation (starch or glucose) and sterilisation; seed fermentation (inoculum train); main fermentation in industrial bioreactors; solid–liquid separation (centrifugation or filtration); purification using resins or ion exchange; concentration, crystallisation and drying; and packaging of the final product.
From an engineering standpoint, the process flow in the United States is identical on paper. The difference lies in the industrial viability of the complete process flow.
Infrastructure and regulatory bottlenecks in the USA
Chinese sources emphasise that plant performance depends as much on auxiliary systems as on the reactors themselves. In China, plants are designed from the ground up for continuous fermentation with oversized utilities, energy integration (cogeneration and low-cost steam), industrial zones with centralised effluent treatment and rapid scaling of CIP/SIP systems. Investment and financing are state and quasi-state, with long amortisation periods and tolerance for low margins.
In the United States, several bottlenecks emerge:
Industrial utilities are costly, and both energy and steam prices are volatile. Energy integration is limited, resulting in higher structural OPEX.
Water and effluents are a critical factor. Amino acid fermentation generates high chemical oxygen demand (COD), ammoniacal nitrogen, salts and organic byproducts. There are fragmented environmental permits (EPA + state + county), very high regulatory uncertainty and strong local opposition known as NIMBY (Not In My Backyard). Effluent treatment can exceed 25–30 percent of CAPEX, with the risk of three to seven years of delays solely in permitting.
CIP and SIP biosecurity standards in the USA are stricter, less flexible and involve heavier documentation requirements, increasing CAPEX, validation timelines and operating costs.
Amino acid fermentation is only profitable at very large industrial scales. Proposed US projects are not as capital-intensive nor comparable to Chinese plants in terms of scale and cost. As a result, facilities are not competitive against Chinese imports. Private capital demands fast returns, low regulatory risk and stable prices; therefore, without state support, large-scale amino acid production projects do not move forward. The letter to President Trump already demonstrates this reality.
Vitamins and microingredients: The core problem
There is a strong concentration of capacity in China. Many key vitamins (vitamin C, folic acid, vitamin A, several B-group vitamins) are produced in massive Chinese plants and integrated chemical complexes. This creates a geographic and KSM (Key Starting Materials) bottleneck.
Dependence on KSMs and intermediates goes beyond the finished product. A large portion of the risk arises from importing KSMs and intermediates that feed the synthesis of APIs and vitamins. If the supply of precursors fails, partial onshoring does not resolve the vulnerability. Large-scale industrialisation in China generates unit costs that the United States cannot match without massive investment and long timelines, discouraging private investment in local plants.
Does the United States have sufficient raw materials? Partially no. The United States has capacity in downstream stages (formulation, packaging and blending) but lacks large-scale domestic production of many KSMs and precursors required to synthesise certain vitamins (e.g., vitamin C, folic acid). This forces reliance on imported KSMs or critical raw materials. While many basic raw materials (alcohols, processed sugars, petrochemical intermediates) are globally available, their conversion into KSMs, intermediates and APIs require dedicated plants and know-how that are concentrated in China. Effective onshoring requires building the entire chain.
Is dependence only on China? China is the dominant source (60–90 percent of global supply for different vitamins). India has growing capacity in APIs and pharmaceutical products and can expand production of certain intermediates; however, India itself depends on China for specific KSMs, meaning diversification toward India does not fully eliminate exposure. Europe has limited capacity; costs and regulations make it difficult to compete with Chinese volumes without subsidies. Latin America can provide agricultural raw materials and sugars (e.g., glucose/sorbitol from sugarcane or corn) if investment is made in industrial capacity.
Supply chain dependence levels:
- Level 1 – Precursors/KSMs: petrochemicals, industrialised sugars, solvents, specialised salts. High concentration in Chinese plants.
- Level 2 – Intermediates/INTs: chemical and bio-fermentative processes. Significant capacity in China; India produces APIs but depends on Chinese INTs.
- Level 3 – APIs/Finished vitamins: synthesis, purification, crystallisation. Strong clusters in Chinese provinces.
Strategic recommendations
Short term (6–18 months):
- Comprehensive audits and mapping of the entire chain (KSM, INT, API, formulation) to identify single points of failure and minimum stock levels
- Establish strategic reserves of critical vitamins and precursors (rotating inventories) to buffer rapid disruptions
Medium term (1–3 years):
- Selective tax incentives and subsidies to attract private investment in KSM plants and purification/pilot processes in the United States
- Public partnerships with India and European producers to co-finance intermediate plants, with clauses for technology transfer and origin verification
Long term (3–7 years):
- Phased onshoring and regional diversification to create clusters in the United States or nearby partners (Canada, Mexico, Brazil/Latin America) to produce from agricultural/sugar-based precursors using greener processes (industrial fermentation where applicable)
- Investment in R&D for alternative routes (biotechnology/fermentation) to produce amino acids and vitamins, reducing dependence on traditional chemical routes
- Implement preferential public procurement policies and government offtake contracts of five to seven years to provide market certainty for new domestic producers
- Establish standards and origin audits to ensure alternative supply chains are not indirectly linked back to China
The path forward
The United States already officially recognises biotechnology and biomanufacturing as strategic sectors under Executive Order 14081, with a whole-of-government approach aimed at supply chain resilience. However, without legislation and multi-year budgeting, the policy is not stable. Strategic priority only works when protected by law and budget, not merely by executive orders.
China used technical catalogues to indicate which products and processes should be expanded. The United States can replicate this effect by using federal lists of critical ingredients and eligibility lists for tax credits, grants, loans and public procurement. This is consistent with how the US already operates sectoral industrial programs.
China reduced costs by creating clusters with shared utilities (energy, steam, water, effluents). The United States recognises the same bottlenecks and already has place-based programmes through USDA and DOE for biomass supply, energy and industrial infrastructure. Competing in vitamins and amino acids is not only about technology; it is about shared infrastructure and strategic location.
China combined stricter environmental requirements with industrial consolidation. The United States can achieve the same effect through one-stop permitting for hubs, clear technical standards by process and tax incentives linked to environmental performance.
China ensured competitiveness by imposing mandatory technical floors and traceability. The United States already has the relevant agencies; the key step is to harmonise critical standards for microingredients and premixes and link them to public procurement.
China achieved scale through implicit demand and patient capital. The United States has equivalent instruments: offtake agreements (guaranteed minimum purchases), DPA Title III (Defense Production Act) to expand strategic industrial capacities and clear precedents of the Department of Defense investing in biomanufacturing for national security reasons. The United States can indeed create scale when it treats a sector as strategic.