On March 1, 2025, President Donald Trump signed an Executive Order (EO) initiating an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of timber, lumber and their derivative products (including paper products, furniture and cabinetry) dumped into the U.S. market. The EO states that such products are “a critical manufacturing industry essential to the national security, economic strength, and industrial resilience of the United States…. [that plays] a vital role in key downstream civilian industries, including construction.” This action triggers an investigation process that could result in new tariffs if the Trump administration determines that U.S. reliance on suppliers abroad poses a threat to national security.

While acknowledging that the United States has ample timber resources, the EO notes that “[t]he current United States softwood lumber industry has the practical production capacity to supply 95 percent of the United States’ 2024 softwood consumption. Yet, since 2016 the United States has been a net importer of lumber.” The EO also notes that the U.S. military “spends over 10 billion dollars on construction. The military also invests in innovative building material technology, including processes to create innovative wood products.” For this investigation, “timber” refers to wood that has not been processed and “lumber” refers to wood that has been processed, including wood that has been milled and cut into boards or planks.

The Secretary of Commerce will initiate a formal investigation and within 270 days submit a report to President Trump with findings and recommendations on potential actions to mitigate any national security threats. Among the factors the investigation will assess are: (i) the current and projected demand for timber and lumber in the United States; (ii) the role of foreign supply chains, particularly of major exporters, in meeting U.S. timber and lumber demand; (iii) the impact of foreign government subsidies and predatory trade practices on U.S. industry competitiveness; (iv) the feasibility of increasing domestic timber and lumber capacity; and (v) 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.

While the Section 232 process allows for public comment and hearings, it is unknown at this time whether Secretary of Commerce Howard Lutnick will direct such a process.

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 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 Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.