In January 2008, the American Trucking Associations hosted a delegation from the China Road Transport Association for two days. The agenda covered operations, truck safety rules, driver training, federal and state tax structure, and environmental regulation. The visitors wanted to know how American trucking grew from local hauling into a national logistics engine. We showed them.
I wrote about that visit for FreightWaves in January and asked who was actually driving the trucks that haul the Department’s freight. Last week, I asked again in three speaking sessions with people who can drive change across departments.
From Oct. 26 to 29, the National Defense Transportation Association and U.S. Transportation Command held their Fall Meeting at the Gaylord Texan in Grapevine, Texas. I spoke in three sessions as vice chair of the NDTA Special Purpose Task Force on Freight Resilience, chaired by retired Maj. Gen. Ed Dorman. I pushed to get Department of Transportation and FMCSA leadership into those rooms with military logistics leaders for one reason. The Department of War moves most domestic surface freight through the civilian trucking industry, and China has quietly been building access there for years. Neither department sees the whole truck.
In their Spring meeting, I spoke and produced two assessment reports which can be found here:
DOW Surface Secuirty Assessment: https://drive.google.com/file/d/16yAkdZf__UeCeSMRSft2yNSXB63CALn9/view?usp=sharing
DOW Emissions Related Assessment: https://drive.google.com/file/d/1ap4blBxGnWG0oYYZrBKEiZnui5z1Dsyr/view?usp=sharing
Here is the whole truck.
On Jan. 2, 2025, the Pentagon added COSCO Shipping, the state-owned Chinese ocean carrier, to its Section 1260H list of Chinese military companies. COSCO operates joint venture container terminals at the ports of Los Angeles, Long Beach and Seattle. Shanghai Zhenhua Heavy Industries, known as ZPMC, makes roughly 80% of the ship-to-shore cranes at U.S. ports, including cranes at strategic seaports the military uses to deploy. MITRE warned in 2024 that China’s LOGINK logistics platform gives Beijing visibility into shipping and supply chains, including the ability to spot shipments of U.S. military cargo on commercial freight.
Washington has started to respond. On June 8, the Department of War expanded the 1260H list to 188 entities. On June 30, Section 805 of the fiscal 2024 National Defense Authorization Act took effect, barring the Department from entering, renewing or extending contracts with listed companies or companies they control. A wider ban on buying goods and services that contain their products starts June 30, 2027.
Every one of those measures stops at the dock. The container comes off a Chinese-made crane, gets tracked on a Chinese-built data platform, and then it goes on a truck. Nobody runs a 1260H check on the truck.
On Feb. 1, 2023, a Chinese high-altitude balloon drifted over Montana, home to the Minuteman III missile fields at Malmstrom Air Force Base. It crossed the country for days before an F-22 shot it down off Myrtle Beach, South Carolina, on Feb. 4. In December 2023, NBC News reported that U.S. intelligence officials had determined the balloon used a commercially available American internet service provider to communicate, mainly for navigation. The provider denied it.
The lesson of the balloon isn’t the balloon. An adversary platform rode American commercial infrastructure over American nuclear sites. China doesn’t need its own network inside this country. It uses ours.
Two months after that story broke, the government went public with a bigger version of the same idea. In February 2024, CISA, the NSA and the FBI warned that Chinese state-sponsored hackers known as Volt Typhoon had burrowed into the networks of U.S. critical infrastructure, including transportation systems, and were pre-positioning to disrupt them in a crisis. Trucks are transportation systems. So are the dispatch inboxes, load boards and telematics portals that tell them where to go.
In January 2025, the Commerce Department’s Bureau of Industry and Security finalized a rule banning connected vehicle software and hardware with a sufficient nexus to China or Russia. Read the fine print. It covers vehicles under 10,001 pounds. BIS pulled heavy trucks from the final rule, citing the complexity of the commercial vehicle supply chain, while also saying it recognized the acute national security threat of foreign adversary involvement in that supply chain. It promised a separate rule for trucks and buses.
OOIDA’s Todd Spencer said at the time that the decision put the issue on the back burner while foreign technologies are already active on U.S. commercial trucks. He was right. As of this summer, vehicles over 10,000 pounds still weren’t covered. The family SUV in the Pentagon parking lot is protected from Chinese connectivity hardware. The Class 8 tractor backing up to the depot dock with a defense load isn’t.
Tactical military vehicles can be exempted from EPA emissions standards under the national security exemption at 40 CFR 1068.225. A JLTV doesn’t derate itself to a crawl because a sensor in its exhaust threw a code, because a fighting vehicle that immobilizes itself on a bad wire is militarily unacceptable.
The commercial tractor hauling that JLTV to the port gets no exemption. Every 2010 and newer on-highway diesel carries EGR, a diesel particulate filter, selective catalytic reduction, diesel exhaust fluid and an engine computer programmed to enforce it all by derating the truck, in the final stage to about 5 mph, until a technician clears the fault. The Department protected the tank and left the switch installed on the truck that carries the tank. EPA’s own DEF page now says the derate strategy has caused needless frustration, operational delays and real economic hardship. EPA proposed replacing derates with audible and visual warnings on July 14, but it’s still a proposal, and as written, the derate framework can continue through model year 2028.
When that system fails, the truck needs a NOx sensor, a DEF pump, a doser or a DPF, and a big share of the replacement parts on the market come out of Chinese factories. Search any Cummins, Detroit or Volvo NOx sensor number on an online parts marketplace and you’ll find page after page of listings marked country of manufacture China, sold direct by factories in Jiangsu, Zhejiang and Guangdong. Some of those parts are fine. Some read wrong the day they’re installed. A bad sensor on a compliant truck doesn’t just fail. It parks the truck on the shoulder, and the derate doesn’t care that the load is on a fixed sail date.
Certification hasn’t kept up. Until July 1, the California Air Resources Board ran the only EPA-recognized path to certify aftermarket emissions parts, a process EPA itself called faulty and backlogged at 12 to 18 months. EPA has now recognized SEMA’s Certified Emissions program as an alternative, which is good news for American parts makers. It does nothing about the uncertified import already sitting in the repair bay, and no one on the defense side tracks which carriers run which parts.
Every SCR truck drinks DEF, and DEF is 32.5% urea. China is the world’s largest urea producer, and it has shown more than once that it will cut exports to protect its own farmers.
In October 2021, China restricted urea exports. South Korea, which then imported nearly all its DEF-grade urea from China, watched about two million diesel trucks become immobilized. The Korean defense ministry released roughly half of its military urea stockpile to civilians to keep freight moving. Australia stood up a national task force that December for the same reason.
This year it happened again. After the Strait of Hormuz closed, China banned exports of many fertilizer categories in March and didn’t reopen urea exports until June, under a quota market participants put around 3.3 million tonnes for 2026. China doesn’t need to fire a shot to slow American military freight. It needs to tighten an export quota on the one fluid every post-2010 diesel in the defense carrier pool can’t run without.
The last layer is the one I know best, because it’s people.
The Army Transportation Command, known as ARTRANS, approves the commercial carriers that haul the Department’s domestic surface freight one four-letter Standard Carrier Alpha Code at a time. Its published approved lists carry a code, a name and an authority type. They don’t carry a DOT number, an officer, an address or a truck count. Nobody reading the list can tell when several codes are the same people, and on the bid screen, every code looks like a separate competitor.
While we have a much deeper story and breakdown coming on chameleon and shared SCAC codes, I paired SCAC codes in the GFM against their FMCSA DOT data, then ran every approved SCAC code against federal, state and roadside records for the DOW, and the short version is this: families of related codes, sharing officers, phones, addresses and DOT numbers, won more than half the loads in eight months of awards. Plenty of those families are legitimate companies that disclose exactly how they’re organized. Some aren’t. In one case we showed anonymized in Grapevine, a code that declares one truck and one driver to FMCSA got 23 heavy-haul bills of lading on one lane, all entered within four minutes. The full research piece on the code data, with the methodology, is coming separately, so I’ll leave it there for now.
Here is why it belongs in a story about China. The same opacity that lets one operator look like four competitors, haul on trucks nobody approved and come back under a new code after one gets pulled is the opacity a hostile actor needs to watch a strategic movement, delay it or put its own people in the cab. A Chinese intelligence service doesn’t have to build that access. The fraudsters already built it, and they rent it out to anybody.
The driver pipeline was the same story until this year. Yisong Huang, a Chinese national, crossed the border illegally in 2023, got a New York commercial license and killed trucker Kerry Smith on I-40 in Tennessee in December 2025. FMCSA’s non-domiciled CDL final rule took effect March 16, and the agency estimated it would remove about 194,000 of roughly 200,000 non-domiciled CDL holders from eligibility over time. That front door is getting locked. The side doors, the broker who hands the load off, the second code at the same address, the truck that isn’t the one on the award, are still open.
Finish the truck rule. BIS said heavy trucks carry an acute national security threat and promised a separate rulemaking almost two years ago. Every month it waits, more connected Class 8 equipment with Chinese-linked hardware and software goes into service on the routes that serve our bases.
Extend the 1260H logic past the prime contractor. If the Department can’t contract with a Chinese military company, it shouldn’t be blind to who controls the carrier, the broker, and the truck that actually touches its freight. Put the DOT number, officers and address on every approved carrier listing, match them against federal and state records, and require the hauling carrier’s DOT number and plate on every bill of lading.
Treat emissions parts and DEF as supply chain security, not truck stop retail. Ask EPA, on the record in docket EPA-HQ-OAR-2026-0728, for the same mission-critical derate relief it already gave emergency vehicles, covering defense freight on fixed sail dates and protective service loads. Pre-position quality-controlled DEF at strategic seaports and major depots. Commission a study of where our DEF-grade urea comes from and how long the defense carrier pool could run if China and Russia closed the tap at the same time.
Keep the two departments at the same table. ARTRANS approves the carrier. FMCSA owns its identity and authority. DOT owns the driver license pipeline. Commerce owns the connected truck. EPA owns the derate. Each one sees a slice. Beijing sees the whole truck.
In 2008, we taught China how American trucking works. They were good students. The question I left in Grapevine is whether we know our own system as well as they do. Right now, I’m not sure we do.
Help
“Dickie” George of the NSA, who is an amusing, lively speaker gave a nonetheless troubling talk nine years ago, in which he recounts a meeting that is all too typical of the bureaucracy in Washington.
Mr. George:
“I guess it was about 2005, they were talking about the critical infrastructure particularly the
.communications infrastructure in the United States, they were taking bids from companies on maintaining that infrastructure and the low bid came from China, so Congress established this committee of senior people from industry to look at that to see whether it was a good idea or not and I got to testify before them and so the testimony went something like this: they said so is this a problem and I said it's a problem
because you're allowing them access and access gives them the opportunity to do something so you are giving them complete access to the maintenance of your infrastructure and if they want to put a time bomb in it or anything they want to do, they have that access and the chair said, so are you telling me that if we sign this contract they're going to sabotage our infrastructure?
Sir I cannot say that they are going to [but] you're giving them the opportunity to.
He said okay, so are you saying that if we don't sign this contract our infrastructure is safe from the Chinese?
And I said I can't say that, you know there could be other ways they could do something.
He said you're not being very helpful.
Apparently I wasn't because they were all there like, what the heck do we do so he said could we talk to the next person? [The] next person was with the Commerce Department, it's a young lady. He said did you hear that testimony? She said yes sir I did. He said what are you thinking?
She said, sir if you are worried that if we sign this contract that Chinese will sabotage our infrastructure we'll put a clause in the contract that says they promise not to, and suddenly they all smiled…”
https://m.youtube.com/watch?v=h-OGHXUtmto&pp=ygUYRGlja2llIGdlb3JnZSBkYXJ0bW91dGgg&ra=m