rfi回应：对进口机器人和工业机械进行第232条国家安全调查

The Center for Security and Emerging Technology (CSET) at Georgetown University offers thefollowing comments in response to theBureau of Industry and Security, Office of StrategicIndustries and Economic Security, U.S. Department of Commerce’srequest for comments onSection232 National Security Investigation of Imports of Robotics and IndustrialMachinery. A policy research organization within Georgetown University’s Walsh School ofForeign Service, CSET provides decision-makers with data-driven analysis on the securityimplications of emerging technologies, focusing on artificial intelligence, advanced computing,and biotechnology. We appreciate the opportunity to offer these comments. This document is approved for public dissemination. The document contains no business-proprietary or confidential information. Document contents may be reused by the government indeveloping theSection 232 National Security Investigation of Imports of Robotics and IndustrialMachineryand associated documents without attribution. Overview Georgetown University’s Center for Security and Emerging Technology (CSET) presents thefollowingresponses to the BIS RFCregarding the Section 232 Investigation on Imports ofRobotics and Industrial Machinery. Thesefacts and observationsare drawn from CSET’s widebody of researchand a forthcoming article examining AI-Robotics convergence and theunderlyingsupplychain supporting robotics.CSET notes that,while the investigation also requestsinformation about industrial machinery (to include CNC machines, metalworking equipment,EDM machinery, and laser and water-cutting machinery), its research has focused more on therobotics supply chain and as a result the comments below are limited torobotics topicsand respondto specific information elicitations where CSET research is responsive. (i)Thecurrent,projected,and optimal demand for robotics and industrialmachinery, and their parts and components in the United States; The leading international robotics association defines a robot as “an actuated mechanismprogrammable in two or more axes with a degree of autonomy, moving within its environment, toperform intended tasks.”1Helpfully, it also explains specifically what they do not consider a robot:software, drones, voice assistants, autonomous cars, ATMs, and smart washing machines are not consideredrobots.2 Robots are often thought of as autonomous mobile robots(AMRs),manipulator arms or humanoids.3There are dozens of other types of robots, including quadruped(dog-like) robots, medical robots (designed to assist with surgery, for example), and collaborativerobots (or “cobots,”) that work with a human-in-the-loop, typically in industrial environments. Ingeneral, all robots typically consist of five core hardware systems: -Structural componentsprovide the physical framework, support, and protection for allother systems. For humanoid robots, as the name implies, these structural components areanthropomorphic and generally are designed to provide joint, weight distribution,movement, and manipulation that mimics human form.-Actuation systemsgenerate and control physical movement. For industrial robotics,these systems rely on precision motors that can operate repeatedly at high speeds,manipulating heavy loads. For humanoid robots, these systems can require moreprecision and less load-bearing ability.-Power systemsprovide and distribute energy to all systems. Industrial robots are usuallyconnected to a fixed power supply, while humanoid robots and AMRs rely on batteries.-Computing systemsprocess sensor data and control robot behavior, with humanoidrobots having the most complex compute stack and industrial robots among the leastcompute-intensive.-Sensor systemsperceive the environment in which the robot operates as well as itsinternal state and include cameras, sensors for depth perception, torque/force, jointposition, and LiDAR. Estimating current, projected, and optimal demand for robots and their components is nearlyimpossible due a lack of a standardized bill of materials (Figure 1) as well as a lack of robust,comprehensive, high-fidelity supply chain data. There are a variety of reasons this data does notexist: most robotics transactions are B2B and private companies do not feel a need to share publicstatistics on their current or future rate of robotic adoption nor their BOMs. Additionally,mostrobotics development is still very nascent (especially in the humanoid sub-market).Thus demandestimates are inherently speculative, and it is unclear if/when commercial adoption at scale willoccur. https://www.wevolver.com/article/robotic-actuators-the-muscle-power-of-industry-40;https://www.sciencedirect.com/science/article/pii/S2666912921000301#sec1;https://standardbots.com/blog/what-are-the-main-components-of-a-robot?;https://www.wevolver.com/article/understanding-amr-robots-a-comprehensive-guide;https://qviro.com/blog/cost-of-autonomous-mobile-robots/;https://qviro.com/blog/how-much-does-a-humanoid-robot-cost/;h