Section 232 Investigations

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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…

On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto…

On May 16, 2025, Customs and Border Protection (CBP) issued a Notice to implement President Donald Trump’s earlier Executive Order (EO) 14289 that eliminated the “stacking” (or accumulation) of certain overlapping tariffs. These overlapping tariffs included the IEEPA tariffs on Canada and Mexico, the Section 232 automobile and automotive part tariffs, and the Section 232…

On May 1, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of commercial aircraft, jet engines, and parts for commercial aircraft and jet engines. Interested parties may submit written…

On May 8, 2025, the White House published general terms for a future trade deal “to enhance [the] economic partnership” between the United States and the United Kingdom. The general terms, which names the forthcoming agreement as the U.S.-UK Economic Prosperity Deal, “do[] not constitute a legally binding agreement” but rather memorialize a set of…

On April 29, 2025, President Trump signed a Proclamation amending the previously announced tariffs on automobile parts used in passenger vehicles and light trucks. This amendment follows Proclamation 10908, which announced 25% section 232 tariffs on imports of certain final, assembled passenger vehicles and light trucks (“automobiles”), effective April 3, 2025, and imports of…

On April 29, 2025, President Donald Trump issued an Executive Order (EO) clarifying that each of the tariffs he has imposed pursuant to the International Emergency Economic Powers Act (IEEPA) and Section 232 of the Trade Expansion Act of 1962, serve separate and distinct policy purposes, but should “not all have a cumulative effect (or ‘stack’…

On April 22, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of medium-duty trucks, heavy-duty trucks, medium- and heavy-duty truck parts, and their derivative products.

The Federal Register notice…

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…