On October 28, 2026, President Trump issued a proclamation titled “Adjusting Imports of Robotics, Industrial Machinery, and Their Parts and Components into the United States,” directing the Secretary of Commerce and the United States Trade Representative (USTR) to jointly pursue negotiations with trading partners to address the national security threat posed by these imports. Rather than imposing tariffs or quotas now, the proclamation makes negotiated agreements the initial remedy.

The action follows a Commerce investigation initiated under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862) (see Update of September 25, 2025). The Secretary found that robotics, industrial machinery, and their parts and components “are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States,” and the President concurred.

According to the proclamation, the Secretary found that:

  • robotics and industrial machinery support production of defense systems such as aircraft, tanks, ships, weapons, and munitions;
  • robotics and industrial machines are crucial to the United States’ critical infrastructure sectors and other key aspects of the United States economy;
  • the United States relies on foreign imports for most types of robotics and industrial machinery and their components, and the value of those imports has increased over the last decade;
  • robotics and machinery from “certain foreign entities pose unique security and safety risks,” including cybersecurity vulnerabilities, because they routinely process and store sensitive data; and
  • domestic industry does not produce enough of these products to meet national security needs.

The proclamation states that, “[d]epending on the status or outcome of such negotiations,” the President “may consider alternative remedies in the future, including imposing or modifying tariffs, duties, quotas, and fees; and establishing a program to incentivize new investment in United States production of robotics and industrial machinery, as well as their parts and components.” It also notes that, under 19 U.S.C. 1862(c)(3)(A), the President may take other actions “to adjust imports to eliminate the threat that the imported article poses to the national security” if an agreement is not entered into within 180 days, is not being carried out, or is ineffective.

The Secretary and USTR must update the President on the negotiations within 180 days of the date of the proclamation. Importers and manufacturers that rely on imported robotics and industrial machinery should consider monitoring these negotiations, as tariffs, quotas, fees, or other actions remain possible.

Notably, the security concerns regarding foreign-sourced robotics echo recent Federal Communications Commission (FCC) actions adding advanced robotic devices and power inverters to the FCC Covered List (see Update of August 4, 2026; see also Update of August 26, 2026).

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Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.

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.

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.