Executive Summary
Major economies like China and India emit more pollution than the United States to produce the same value of goods. High-altitude winds carry this foreign pollution long distances to U.S. shores, damaging America’s air quality. Foreign-produced pollution elevates West Coast ozone levels by up to 20% seasonally, while particulate matter produced abroad causes an estimated 8,000 premature deaths and over $60 billion in health care costs in the United States annually.
Meanwhile, foreign pollution has contributed to “nonattainment” designations in at least 85 U.S. counties, meaning these areas fail to meet federal air-quality standards in part because of foreign-produced pollutants. This status forces states to tighten pollution controls to maintain healthy air quality, which can delay industrial permits and limit manufacturing operations even for low-polluting firms. The United States currently lacks a legal framework to exclude routine foreign pollution from nonattainment designations, but creating new exemptions would weaken air-quality protections to the detriment of public health. Additional policy solutions are needed to address foreign pollution at its source, such as investment in intercountry pollution monitoring to better understand the scope of the problem and targeted pollution tariffs to encourage improved environmental practices abroad.
Introduction
Shifts in global manufacturing have concentrated industrial production in economies with lax environmental standards and enforcement. In many instances, foreign companies leverage government policies to subsidize and expand industries that depend on outdated, low-cost, environmentally irresponsible practices.[1] This undercuts U.S. manufacturers that maintain higher environmental and labor standards, which has a compounding effect on American jobs, U.S. national security, and the planet’s climate.[2]
This issue brief shows how foreign pollution threatens U.S. public health and manufacturing directly. Winds sweep foreign-produced air pollutants, distinct from greenhouse gases (GHGs), across oceans and continents into America’s atmosphere.[3] These intrusions contribute to respiratory, cardiovascular, and neurological diseases, which have been linked to premature deaths across the country.[4]
Moreover, foreign pollution constrains American manufacturing by filling up maximum pollution thresholds. The Environmental Protection Agency (EPA) designates certain geographic areas as being in “nonattainment” when they do not meet federal air quality standards for specific pollutants under the Clean Air Act. When foreign pollution contributes to a county receiving a nonattainment designation, it unfairly restricts American industry by curbing manufacturing activity and blocking permits for new industrial facilities.
This issue brief examines the multifaceted effects that foreign pollution has on U.S. environmental and economic security. It evaluates the sufficiency of existing domestic countermeasures and recommends policies that could reduce foreign pollution levels at the source—long before foreign pollutants arrive in the United States. For more on the scale of foreign pollution relative to U.S. levels and its pathways into the U.S. atmosphere, see Appendix I and II.
Impacts of Foreign Pollution on the United States
When major manufacturing hubs abroad operate without sufficient environmental standards, the consequences are global. Foreign pollution is a problem that harms American citizens directly.
Table 1. Estimated Annual Impacts of Foreign Pollution on the United States
ImpactEstimated Number (annual)Specific CausePremature Deaths8,000Breathing of particulate matter pollutionHealth Care Costs$60BIncreased medical expenses, rehabilitation, prescription medications, lost wagesCounties with Nonattainment Designations85+Western U.S. counties affected by foreign pollution and designated as being in nonattainment
Sources: Nature[5], NRDC[6] , and EPA[7]
Threat to Public Health
Foreign pollution exacts a heavy toll on America’s public health. Trans-Pacific ozone and particulate matter from Asian sources contribute to thousands of premature deaths annually in the Western United States, alongside nonfatal respiratory, cardiovascular, and neurological illnesses.[8] The EPA links elevated levels of ozone, black carbon, and carbon monoxide to adverse outcomes, including heart attacks, asthma exacerbation, lung damage, and premature mortality.[9]
Overall, air pollution in the United States imposes health and economic costs exceeding $800 billion annually,[10] with foreign-sourced contributions representing a portion that disproportionately affects vulnerable border and coastal communities. For example, estimates suggest that foreign-produced pollution causes more than $60 billion in U.S. health care costs per year.[11]
Threat to Manufacturing
Under the Clean Air Act, states must meet National Ambient Air Quality Standards (NAAQS) for six criteria pollutants, including ozone and particulate matter. [12] This means that foreign pollution can limit American companies even on American soil, if the levels of a particular pollutant are near or exceed the NAAQS in the area where the company operates.
At least 85 counties impacted by Chinese pollution are in nonattainment for criteria pollutants,[13] meaning that they do not meet federal air-quality standards. This status can block industrial permits and inhibit manufacturing growth, even for U.S. firms that operate with low levels of pollution, by requiring states to adopt and enforce State Implementation Plans to lower pollution levels.[14] This “exported nonattainment” from other countries stifles economic activity in border and Western states, exacerbating job losses due to high-polluting competitors abroad.[15] Recent nonattainment designations leading to tighter restrictions, such as in Phoenix-Mesa, AZ, explicitly cite international pollution as a factor in pushing local air-quality levels above federal standards.[16]
Gaps in U.S. Law for Foreign Pollution and the Public Health Consequences of Weakening Standards
Current U.S. law limits the ability to exclude routine foreign pollution from nonattainment designations,[17] and for good reason. Attempts to create additional exceptions for these foreign pollution sources would endanger American public health because they would increase domestic pollution levels overall.
No Mechanism Exists to Exclude Persistent Foreign Pollution
Existing legal frameworks provide little relief for the contribution of foreign pollution to nonattainment designations. The Cross-State Air Pollution Rule (CSAPR), for instance, targets domestic interstate pollution by requiring 28 Eastern states to cut power plant emissions of sulfur dioxide (SO₂) and nitrogen oxides (NOx)—but it entirely ignores foreign sources.[18] This lapse leaves trans-Pacific or cross-border contributions unaddressed despite their role in exacerbating nonattainment across the country.
The “exceptional events” rule under the Clean Air Act does allow states to submit a request to exclude certain pollution events from nonattainment calculations. This exception, however, is designed only for “exceptional events”: pollution from natural events like wildfires or human-caused activities that are unlikely to reoccur.[19] Routine pollution from foreign sources does not qualify.
Exclusions for Foreign Pollution Could Endanger Public Health
Despite the potential benefits for domestic manufacturing, carve-outs for persistent foreign pollution would come at a cost to public health. If foreign pollution is excluded from nonattainment designations, the result would be higher acceptable levels of pollution in the United States. Maintaining healthy pollution levels is critical to protect Americans from harmful overexposure to pollutants. As a result, reforms to existing standards are insufficient to address the full scope of the problem.
A more targeted approach is needed to reduce foreign pollution before it occurs, balancing the protection of American public health with the best interests of U.S. manufacturing.
Conclusion and Policy Recommendations
Foreign pollution is a danger to American lives, jobs, and the economy. Mitigation will require an increased ability to evaluate foreign pollution and action to lower high pollution levels at their sources. To accomplish this goal, U.S. domestic policy should:
- Invest in Pollution Monitoring: Allocate resources for advanced monitoring of transboundary pollutants, including through satellite networks, to better understand the scope of the problem.
- Leverage Trade Tools: Impose border pollution adjustments or pollution tariffs on imports to encourage improved pollution control abroad.
- Promote Clean Tech Exports: Incentivize U.S. exports of low-pollution and pollution-control technologies to countries with outdated, inefficient equipment.
- Pursue Targeted Diplomacy: Prioritize bilateral agreements with key polluters (e.g., U.S.-China-Mexico), ensuring that these agreements target high-impact pollutants, such as particulate matter.
- Integrate Metrics Into Trade Agreements: Embed foreign pollution metrics and standards into international agreements.
If implemented, measures that pursue these objectives could level the playing field for clean producers in the United States, protect public health from harmful foreign pollutants, and mitigate the threat of foreign pollution to domestic manufacturing.
Appendix
I. Relative Pollution Abroad Far Exceeds U.S. Levels
Most major economies, particularly those engaged in noncompetitive industrial practices like China, emit far higher levels of pollution than the United States relative to their economic output. For instance, compared with U.S. producers, Chinese manufacturers emit approximately four times more nitrogen oxide (NOx), six times more particulate matter (PM2.5), seven times more sulfur dioxide (SO2), and 19 times more carbon monoxide (CO) to produce the same value of goods (see Figure 1). The EPA sets limits on domestic levels of all four of these gases, classified as “criteria pollutants,” due to their harmful effects on human health and the environment.
Figure 1. Pollution intensity for the U.S., China, and India
Source: Climate Leadership Council[20]
China is the largest global polluter, accounting for about 56% of the world’s coal use.[21] In addition to releasing 32% of global greenhouse gas (GHG) emissions, China contributes a high percentage of the world’s non-GHG pollution.[22]
Poor air quality resulting from inadequate regulation of these pollutants has led to up to 2 million premature deaths per year in China.[23] In the past, enforcement of environmental standards in China has been largely left to local government officials. For example, environmental inspectors in northern China investigated 20,000 businesses in 2017 and found that 70% failed to meet standards for air pollution control.[24] Companies were emitting more than their reported quantities, operating with insufficient pollution control equipment, and operating in unauthorized locations.
India presents a comparable challenge. Unregulated industrial practices contribute to high levels of criteria pollutants in India,[25] while the country continues to rely on pollution-intensive coal to generate 70% of its electricity.[26] Compared to U.S. producers, Indian manufacturers emit approximately 7 times more nitrogen oxide (NOx), 13 times more carbon monoxide (CO), 21x more particulate matter (PM2.5), and 35 times more sulfur dioxide (SO2) to produce the same value of goods (see Figure 1).
Poor air quality in India results in 1.67 million premature deaths annually[27] and economic losses of $36.8 billion from declines in health and productivity.[28] In northern India, inspections frequently reveal factories operating with inadequate pollution controls, mirroring pollution enforcement challenges in China.[29]
Disparities in pollution levels, as showcased by China and India, not only fuel disproportionate increases in global emissions but also result in significant non-GHG pollution that is exported directly to the United States.
II. Foreign Pollution Affects U.S. Air Quality
Pollutants produced abroad infiltrate the atmosphere over the United States via long-range atmospheric transport—high-altitude winds that carry pollutants over oceans and continents alike.[30] Air pollutants can be carried thousands of miles, from the mercury emitted by coal-burning power plants abroad to the particulate matter and sulfur dioxide that steel plants emit when they do not properly dispose of waste.[31]
Although most research on long-range pollution movement was conducted in the 2000s and early 2010s, trends strongly indicate that pollution from countries like China continues to affect U.S. air quality. Chinese coal use, for example, increased by roughly 20% between 2010 and 2022.[32]
Atmospheric modeling shows that prevailing westerly winds and jet streams enable trans-Pacific movement of pollutants from Asia to America’s West Coast, while pollution from Canada and Mexico affect air quality in U.S. border states.[33] Fluctuations in wind patterns throughout the year create seasonal peaks in the spring.
Examples
- Ozone: Ground-level ozone forms when pollutants such as nitrogen oxides (NOx) and volatile organic compounds (VOCs) react with sunlight. Models have found that ozone pollutants transported across the Pacific Ocean from Asia add an average of 5-7 parts per billion by volume (ppbv) to surface ozone levels in the Western United States and 2-5 ppbv to levels in the Eastern United States (see Figure 2).[34] For comparison, the EPA’s health-based standard for ozone levels is capped at 70 ppbv.[35] During seasonal peaks in the spring, concentrated plumes of ozone from Asia can contribute 8-15 ppbv, accounting for up to 20% of total permitted ozone levels in certain U.S. states.[36] Roughly half of these transported ozone emissions come from China.[37]
Figure 2. Illustration of how Asian pollution increases ozone concentrations over different parts of the U.S. within a sample one-month period.
Source: Atmospheric Chemistry and Physics [38]
- Other pollutants: Fine particles like sulfates and black carbon from Asian industrial production and biomass burning affect California, Oregon, Washington, and similar states. Trans-Pacific aerosols contribute 6%–18% of U.S. black carbon and up to 36% of particulate matter (PM₂.₅) in affected areas.[39] Asian coal plants emit mercury that circulates globally, contributing 14%–17% to U.S. mercury levels.[40] Chinese pollution also adds 8%–28% to Western U.S. levels of sulfur dioxide and 9%–14% to levels of carbon monoxide.[41]
[1] Joseph S. Shapiro and Reed Walker, “Why Is Pollution from U.S. Manufacturing Declining? The Roles of Environmental Regulation, Productivity, and Trade,” American Economic Review, 108(12): 3814-3854, December 2018. Available at: https://www.aeaweb.org/articles?id=10.1257/aer.20151272.
[2] Catrina Rorke, Scott Nystrom, and Daniel Hoenig, “America’s Carbon Advantage 2025,” Climate Leadership Council, March 2025. Available at https://clcouncil.org/report/americas-carbon-advantage-2025/.
[3] NASA Jet Propulsion Laboratory, “Nature, Chinese Pollution Offset U.S. West Ozone Gains,” August 10, 2015. Available at: https://www.jpl.nasa.gov/news/nature-chinese-pollution-offset-us-west-ozone-gains/?referrer=grok.com.
[4] Environmental Protection Agency, “Health Effects of Ozone Pollution.” Available at: https://www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution; Environmental Protection Agency, “Particle Pollution and Respiratory Effects.” Available at https://www.epa.gov/pmcourse/particle-pollution-and-respiratory-effects.
[5] Estimate for the annual premature deaths comes from Qiang Zhang, Xujia Jiang, et al., “Transboundary Health Impacts of Transported Global Air Pollution and International Trade,” Nature, 543(7647): 707, Figure 2a, 2017. Available at: https://www.nature.com/articles/nature21712.
[6] The estimate for annual health care costs is based on the valuation of premature deaths, productivity losses, and medical costs in “The Costs of Inaction: The Burden of Climate Change on Health,” Natural Resources Defense Council, 4, 2021. Available at: https://www.nrdc.org/sites/default/files/costs-inaction-burden-health-report.pdf. BPC multiplied NRDC’s numbers by the number of deaths attributed to foreign pollution specifically by Qiang Zhang, Xujia Jiang, et al., “Transboundary Health Impacts…,” Nature, pg. 707, Figure 2.a.
[7] Estimates for foreign-impacted nonattainment designations stem from authors’ calculations using Environmental Protection Agency, “Green Book: Nonattainment Areas for Criteria Pollutants; Clean Air Fund,” 2025. Available at: https://www.epa.gov/green-book.
[8] Environmental Protection Agency, “Health Effects of Ozone Pollution;” Available at: https:// www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution.
[9] Environmental Protection Agency, “Health Effects of Particulates and Black Carbon.” Available at: https://www.epa.gov/sites/default/files/2014-05/documents/health-effects.pdf.
[10] Natural Resources Defense Council, “The Costs of Inaction: The Burden of Climate Change on Health,”, 2021, Available at: https://www.nrdc.org/sites/default/files/costs-inaction-burden-health-report.pdf.
[11] See Endnote 6.
[12] Environmental Protection Agency, “Summary of the Clean Air Act,” 2025. Available at: https://www.epa.gov/laws-regulations/summary-clean-air-act.
[13] Environmental Protection Agency, “Green Book: Nonattainment Areas for Criteria Pollutants; Clean Air Fund,” 2025. Available at: https://www.epa.gov/green-book.
[14] Joseph S. Shapiro and Reed Walker, “Where is Pollution Moving? Environmental Markets and Environmental Justice,” NBER Working Paper 28389, January 2021. Available at: https://www.nber.org/papers/w28389.
[15] Ibid.
[16] “Determination of Attainment by the Attainment Date but for International Emissions for the 2015 Ozone NAAQS: PhoenixMesa Nonattainment Area,” Federal Register, 90(221): November 19, 2025. Available at: https://www.federalregister.gov/documents/2025/11/19/2025-20357/determination-of-attainment-by-the-attainment-date-but-for-international-emissions-for-the-2015.
[17] Note that there is a legal framework for factoring foreign pollution into the severity of nonattainment classification under Section 179B of the Clean Air Act. See “42 U.S.C. §7509a – International border areas,” Cornell Law School. Available at: https://www.law.cornell.edu/uscode/text/42/7509a.
[18] Environmental Protection Agency, “Cross-State Air Pollution Rule (CSAPR),” 2025. Available at: https://www.epa.gov/Cross-State-Air-Pollution.
[19] Environmental Protection Agency, “Treatment of Data Influenced by Exceptional Events; Final Rule,” Federal Register, 81(191): October 3, 2016. Available at: https://www.federalregister.gov/documents/2016/10/03/2016-22983/treatment-of-data-influenced-by-exceptional-events.
[20] Scott Nystrom, “Country-level Analysis of Traditional Air Pollution Intensity,” Climate Leadership Council, February 25, 2026. Available at: https://www.clcouncil.org/blog/pollution-intensity/.
[21] International Energy Agency, “Coal Mid-Year Update,” July 2025. Available at: https://www.iea.org/reports/coal-mid-year-update-2025.
[22] Carbon Brief, “Analysis: China’s CO2 Emissions Have Now Been Flat or Falling for 18 Months,” February 4, 2025. Available at: https://www.carbonbrief.org/analysis-chinas-co2-emissions-have-now-been-flat-or-falling-for-18-months/.
[23] Aristeidis K. Georgoulias, Jos Lelieveld, et al., “Avoided Mortality by Particulate Air Pollution Control Measures in China,” Science of the Total Environment, 2025. Available at: https://www.sciencedirect.com/science/article/pii/S0048969725022065.
[24] Xiang Bo, “Inspections find 70 pct of firms violated environmental rules,” Xinhua Net, June 11, 2017. Available at: http://www.xinhuanet.com//english/2017-06/11/c_136356860.htm.
[25] World Bank Group, “How is India Trying to Address Air Pollution?” June 5, 2024. Available at: https://www.worldbank.org/en/country/india/publication/catalyzing-clean-air-in-india.
[26] Ember, “India,” 2026. Available at: https://ember-energy.org/countries-and-regions/india/.
[27] BC News, “The human toll of air pollution in India,” Boston College2025. Available at: https://www.bc.edu/bc-web/bcnews/nation-world-society/international/air-pollution-in-inda.html.
[28] World Bank, “How Is India Trying to Address Air Pollution?” 2024/2025, Available at: https://www.worldbank.org/en/country/india/publication/catalyzing-clean-air-in-india.
[29] Garvit Bhirani, “Air Pollution: CAQM orders closure of 16 industrial units in Rajasthan, Uttar Pradesh, Haryana over gross violations,” Mint, January 9, 2026. Available at: https:// www.livemint.com/news/india/air-pollution-caqm-orders-closure-of-16-industrial-units-in-rajasthan-uttar-pradesh-haryana-over-gross-violations-11767970582778.html.
[30] National Academy of Sciences, “Global Sources of Local Pollution: An Assessment of Long Range Transport of Key Air Pollutants To and From the United States,” 2009. Available at: https://nap.nationalacademies.org/resource/12743/global_sources_brief_final.pdf; Environmental Protection Agency, Total Maximum Daily Loads (TMDLs). Available at: https://www.epa.gov/tmdl/overview-total-maximum-daily-loads-tmdls.
[31] Meiyun Lin, Arlene M. Fiore, et al., “Transport of Asian Ozone Pollution into Surface Air over the Western United States in Spring,” Journal of Geophysical Research: Atmospheres, 117: 2012. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2011JD016961.
[32] Scott Nystrom, “Why is U.S. industry 3x more carbon efficient than China?” Climate Leadership Council, February 4, 2025. Available at: https://clcouncil.org/blog/why-is-u-s-industry-3x-more-carbon-efficient-than-china/.
[33] Charles L. Heald, Daniel J. Jacob, et al., “Transpacific Transport of Asian Anthropogenic Aerosols,” Journal of Geophysical Research: Atmospheres, 111: 2006/2025. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2005JD006847.
[34] Ppbv describes the number of pollutant molecules per billion air molecules.
[35] Environmental Protection Agency, “Ozone National Ambient Air Quality Standards (NAAQS).” Available at: https://www.epa.gov/ground-level-ozone-pollution/ozone-national-ambient-air-quality-standards-naaqs.
[36] O. R. Cooper, D. D. Parrish, et al., “Increasing springtime ozone mixing ratios in the free troposphere over western North America,” Nature. Available at: https://www.nature.com/ articles/nature08708, as cited in Meiyun Lin, Arlene M. Fiore, et al., “Transport of Asian Ozone Pollution into Surface Air over the Western United States in Spring,” Journal of Geophysical Research: Atmospheres, 117: 2012. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2011JD016961.
[37] NASA Jet Propulsion Laboratory, “Nature, Chinese Pollution Offset U.S. West Ozone Gains,” August 10, 2015. Available at: https://www.jpl.nasa.gov/news/nature-chinese-pollution-offset-us-west-ozone-gains.
[38] Figure is from p. 1630 of L. Zhang, D. J. Jacob, et al., “Transpacific Transport of Ozone Pollution and the Effect of Recent Asian Emission Increases on Air Quality in North America: An Integrated Analysis Using Satellite, Aircraft, Ozonesonde, and Surface Observations,” Atmospheric Chemistry and Physics, 8: 6117–6136, October 22, 2008. Available at: https://acp.copernicus.org/articles/8/6117/2008/.
[39] Colette L. Heald, Daniel J. Jacob, et al., “Transpacific Transport of Asian Anthropogenic Aerosols and Its Impact on Surface Air Quality in the United States,” Journal of Geophysical Research: Atmospheres, 111: July 22, 2006. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2005JD006847; OL. Hadleyet al., “TransPacific transport of black carbon and fine aerosols (D < 2.5 μm) into North America,” Journal of Geophysical Research: Atmospheres, 112: 2007. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2006JD007632; Zhiyuan Hu, Jianping Huang, et al., “TransPacific Transport and Evolution of Aerosols: Spatiotemporal Characteristics and Source Contributions,” Atmospheric Chemistry and Physics, 19: 12709–12727, 2019. Available at: https://acp.copernicus.org/articles/19/12709/2019; Junfeng Liu, Denise Leonore Mauzerall, and Larry W. Horowitz, “Evaluating inter-continental transport of fine aerosols: (2) Global health impact,” Atmospheric Environment, 43(28: 4339–4347, 2009. Available at: https://collaborate.princeton.edu/en/publications/evaluating-inter-continental-transport-of-fine-aerosols2-global-h/.
[40] Sarah A. Strode, Lyatt Jaeglé, et al., “TransPacific transport of mercury,” Journal of Geophysical Research: Atmospheres, 113: August 7, 2008. Available at: https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2007JD009428; ScienceDirect, “Export of Atmospheric Mercury from Asia,” 2025. Available at: https://www.sciencedirect.com/science/article/abs/pii/S1352231005001159.
[41] David Kirby, “Made in China: Our Toxic, Imported Air Pollution,” Discover, March 17, 2011. Available at: https://www.discovermagazine.com/made-in-china-our-toxic-imported-air-pollution-3125.
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