Section 232 Investigations

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In Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts into The United States,” on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new interim final rule published on September 17…

On September 17, 2025, the Bureau of Industry and Security (BIS) published a Federal Register notice that it will again accept requests for new derivative products to be subject to Section 232 tariffs on steel and aluminum articles. The request window is open from September 15 through September 29, 2025. Requests must provide detailed information…

Executive Order 14346 (EO 14346) provides new procedures for implementing trade and security agreements and modifies the Trump administration’s approach to reciprocal tariffs. EO 14346 builds on previous trade actions, particularly those established under EO 14257, by expanding Annex II to EO 14257 – the list of items that are exempt from the reciprocal tariffs…

On August 13, 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 wind turbines and their parts and components. Interested parties may submit written comments, data, analyses, or other information to the…

On August 21, 2025, the White House published a joint statement from the United States and the European Union (“EU”) announcing “key details” of a Framework on an Agreement on Reciprocal, Fair, and Balanced Trade (“Framework Agreement”). Though presented as a new accord, the Framework Agreement elaborates on a trade deal first announced in late July…

On August 15, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Federal Register notice adding 407 codes from the Harmonized Tariff Schedule of the United States (HTSUS) to the list of steel and aluminum derivative products. As a result, these products will now be subject to the Section 232 tariff…

Following a threat posted on his social media site Truth Social in early July, President Donald Trump issued an Executive Order (“EO”) on July 30, 2025, imposing an additional 40% tariff on U.S. imports from Brazil, effective August 6, 2025.  With the 10% baseline reciprocal tariff established by President Trump’s April 2, 2025 EO, tariffs…

Update:  On July 31, 2025, Customs and Border Protection (CBP) released Cargo Systems Messaging Service (CSMS) # 65794272 providing guidance on applying the 50% Section 232 ad valorem duty on all imports of semi-finished copper products and intensive copper derivative products imposed by President Donald Trump on July 30, 2025. This guidance provides instructions on…

On July 1, 2025, the Department of 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 unmanned aircraft systems (UAS) and their parts and components. The Department’s Bureau of Industry and Security (BIS) subsequently issued a Notice…

On July 1, 2025, the Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act, as amended, to determine the effects on the national security of imports of polysilicon and its derivatives (items considered to be critical solar energy inputs). The Department’s Bureau of Industry and Security (BIS) subsequently issued a…