On April 15, 2025, President Donald Trump issued an Executive Order (EO) directing the Department of Commerce (Commerce) to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of processed critical minerals and their derivative products. Because “processed critical minerals and their
Section 232 Investigations
Commerce Initiates Section 232 National Security Investigation of Imports of Semiconductor Manufacturing Equipment
On April 1, 2025, it was announced that the Department of Commerce had initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of imports of semiconductors and semiconductor manufacturing equipment (SME), and their derivative products. This includes, among other things, semiconductor substrates and…
Commerce Initiates Section 232 National Security Investigation of Imports of Pharmaceuticals & Pharmaceutical Ingredients
On April 1, 2025, it was announced that the Department of Commerce had initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of pharmaceuticals and pharmaceutical ingredients and their derivative products. This includes both finished generic and non-generic drug products, medical countermeasures, critical…
Annex Identifying Scope of Automobiles and Automobile Parts Subject to Section 232 Tariffs Is Released
On April 2, 2025, the Annex to the Presidential Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts was released along with U.S. Customs and Border Protection (US-CBP) guidance regarding the fully assembled automobile provisions. As previously reported, see Thompson Hine Update…
President Trump Announces Section 232 Tariffs of 25% on Imports of Automobiles and Certain Auto Parts
On March 26, 2025, President Donald Trump issued a Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts, citing “a critical threat to U.S. national security.” The tariffs will apply to final assembled automobiles, entered for consumption or withdrawn from warehouse for…
BIS Seeks Public Comments on Section 232 Investigations of Imports of Copper and Lumber
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…
Trump Administration Imposes Section 232 Steel and Aluminum 25% Tariffs March 12, 2025; EU and Canada Retaliate
As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2025, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs.
Trump Administration Initiates Section 232 Investigation into Imports of Timber and Lumber that May Lead to New Tariffs
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…
Trump Administration Initiates Section 232 Investigation into Imports of Copper and Copper Derivatives That May Lead to New Tariffs
On February 25, 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 copper in all forms, including but not limited to: (i) raw mined copper; (ii) copper concentrates; (iii) refined copper; (iv) copper alloys; (v) scrap copper…
White House Releases Annexes of Steel & Aluminum Derivative Items Subject to Section 232 25% Tariffs

On February 14, 2025, the White House released annexes specifying steel (see page 24) and aluminum (see page 19) derivative items that will be subject to the 25% tariffs under Section 232, as announced by President Trump on February 10, 2025. For further details, refer to our blog post of February 12, 2025.
The…