Department of Commerce Initiates Section 232 Investigation of Imports of Robotics and Industrial Machinery

On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of robotics and industrial machinery. According to the notice, the term “robotics and industrial machinery” for this investigation includes, among other things, robots and programmable, computer-controlled mechanical systems; further details are provided in the notice.  Interested parties may submit written comments, data, analyses, or other information to the Office of Strategic Industries and Economic Security at Commerce’s Bureau of Industry and Security (BIS) no later than October 17, 2025.

BIS is particularly interested in comments addressing:

1. The current, projected, and optimal demand for robotics and industrial machinery, and their parts and components in the United States;
2. The extent to which domestic production of robotics and industrial machinery, and their parts and components can meet domestic demand;
3. The role of foreign supply chains, particularly of major exporters, in meeting U.S. demand for robotics and industrial machinery, and their parts and components;
4. The concentration of U.S. imports of robotics and industrial machinery, and their parts and components, from a small number of suppliers or foreign nations and the associated risks;
5. The impact of foreign government subsidies and predatory trade practices on the competitiveness of the robotics and industrial machinery, and their parts and components, in the United States;
6. The economic impact of artificially suppressed prices of robotics and industrial machinery, and their parts and components, due to foreign unfair trade practices and state-sponsored overproduction;
7. The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of robotics and industrial machinery, and their parts and components;
8. The feasibility of increasing domestic capacity for robotics and industrial machinery, and their parts and components, to reduce import reliance;
9. The impact of current trade policies on domestic production of robotics and industrial machinery, and their parts and components, and whether additional measures, including tariffs or quotas, are necessary to protect national security;
10. The impact of the use or lack of use of robotics and industrial machinery on U.S. manufacturing employment;
11. The potential for foreign control or exploitation of the robotics and industrial machinery supply chain;
12. The ability of foreign persons to weaponize the capabilities or attributes of foreign-built robotics and industrial machinery, and their parts or components;
13. The future role of robotics and industrial machinery in the production of items essential to national security or in activities related to national security; and
14. Any other relevant factors.

Comments must be submitted via the federal rulemaking portal at www.regulations.gov. The Docket ID for the request for public comments regarding this Section 232 investigation is BIS-2025-0257, and submitters must refer to XRIN 0694-XC138 in all comments. In initiating this investigation, the Secretary of Commerce must, within 270 days, submit a report to President Donald Trump with findings and recommendations on potential actions to mitigate any national security threats. While the Section 232 process allows for public hearings, it is unknown at this time whether Secretary of Commerce Howard Lutnick will direct such a process.