The Department of Commerce’s Bureau of Industry and Security (BIS) has issued Federal Register notices announcing that interested parties may submit written comments, data or other information pertinent to these investigations. Comments are due no later than April 1, 2025.

Section 232 National Security Investigation of Imports of Copper

This investigation was initiated on February 25, 2025 (see Thompson Hine Update of February 25, 2025). BIS Issued a Notice on March 13, 2025 announcing that it was seeking public comments. BIS is particularly interested in comments addressing the following: (i) the current and projected demand for copper in U.S. defense, energy, and critical infrastructure sectors; (ii) the extent to which domestic production, smelting, refining, and recycling can meet demand; (iii) the role of foreign supply chains, particularly from major exporters, in meeting U.S. demand; (iv) the concentration of U.S. copper imports from a small number of suppliers and the associated risks; (v) the impact of foreign government subsidies, overcapacity, and predatory trade practices on U.S. industry competitiveness; (vi) the economic impact of artificially suppressed copper prices due to dumping and state-sponsored overproduction; (vii) the potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over refined copper supplies; (viii) the feasibility of increasing domestic copper mining, smelting, and refining capacity to reduce import reliance; and (ix) the impact of current trade policies on domestic copper production and whether additional measures, including tariffs or quotas, are necessary to protect national security. Comments must be submitted via the Federal rulemaking portal at: www.regulations.gov. The Docket ID no. for this notice is BIS– 2025–0010, and submitters must refer to X–RIN 0694– XC116 in all comments.

Section 232 National Security Investigation of Imports of Timber and Lumber

This investigation was initiated on March 1, 2025 (see Thompson Hine Update of March 3, 2025). BIS issued a Notice on March 13, 2025 announcing that it was seeking public comments. BIS is particularly interested in comments addressing the following: (i) the current and projected demand for timber and lumber in the United States; (ii) the extent to which domestic production of timber and lumber can meet domestic demand; (iii) the role of foreign supply chains, particularly of major exporters, in meeting U.S. timber and lumber demand; (iv) the impact of foreign government subsidies and predatory trade practices on U.S. timber, lumber, and derivative product industry competitiveness; (v) the feasibility of increasing domestic timber and lumber capacity to reduce imports; (vi) the impact of current trade policies on domestic timber, lumber, and derivative product production, and whether additional measures, including tariffs or quotas, are necessary to protect national security; and (vii) any other relevant factors. Comments must be submitted via the Federal rulemaking portal at: www.regulations.gov. The Docket ID no. for this notice is BIS– 2025–0011, and submitters must refer to X–RIN 0694– XC117 in all comments.

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Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.