Section 232 Explained

Trying to stay ahead of the curve here. The tariff story of the month is the impending imposition of Section 301 tariffs on the 60 countries investigated for forced labor practices. That is expected on or around July 24, when the Section 122 tariffs expire, although as that date approaches, it appears action may be a bit later. If so, there would be a tariff gap—a few days when only the original most-favored-nation tariffs and those imposed pursuant to Section 232 would be in effect. In theory, that would be an opportunity for importers to cram as much into the United States as they can, but in reality, because ocean shipping is measured in weeks, affected merchandise is already en route. The biggest impact will be on already overworked customs authorities who will have to adjust all the tariff schedules after July 24, and then do it over again once the Section 301 tariffs go into effect.

Meanwhile, attention will turn to the 16 overcapacity investigations underway but with no announced conclusions, and to the growing number of Section 232 investigations that have wrapped up or are ongoing. To refresh your memories, Section 232 of the Trade Expansion Act of 1962 authorizes the president to take action against imports he has determined pose a national security threat. The investigations are conducted by the Department of Commerce, which has 270 days to complete its work and submit a report and recommendations to the president, who then has 90 days to decide what, if anything, to do. There is no penalty for missed deadlines, which is convenient, since there are a growing number of them.

Although all of Trump’s tariffs have been, or will be once they are imposed, subject to lawsuits, it is generally agreed that Section 232 tariffs will be the most difficult to defeat in court. The statute’s authority is broad, and judges are reluctant to second-guess a presidential determination that something is a national security threat. At the same time, some of these tariffs, particularly those on steel and aluminum, have proved to be the most impactful—and controversial—tariff actions taken, largely because they have been applied not only to the basic product but to a long list of downstream derivative products.

Section 232 has been a popular tool for Trump. Since he came into office the second time, the Department of Commerce has begun 13 investigations covering a wide variety of items. Here is their status. (Steel and aluminum tariffs began in Trump’s first term. An auto investigation was completed in Trump’s first term, but tariffs were not imposed until his second. The initial tariff was 25 percent but was reduced to 10 or 15 percent for most imports via subsequent trade agreements.)

• Copper. Initiated March 10, 2025. Status: Completed. A 50 percent tariff on the copper content of covered semi-finished and derivative products effective August 1, 2025.
• Timber and Lumber. Initiated March 10, 2025. Status: Global tariffs structured at 10–25 percent. Specific allies received modified levels, including 10 percent for the United Kingdom and 15 percent the European Union, Japan, and South Korea. (Initially announced separately, an investigation on kitchen cabinets, bathroom vanities, and other furniture was folded into the lumber investigation and tariffs of 25 percent were imposed effective October 14, 2025. An announced increase to 50 percent was postponed from January 1, 2026, to January 1, 2027.)
• Semiconductors and Manufacturing Equipment. Initiated April 1, 2025. Status: Trump announced on January 14, 2026, a 25 percent tariff on a narrow set of advanced semiconductor imports and directed the U.S. Trade Representative to pursue further global supply chain negotiations.
• Pharmaceuticals and Pharmaceutical Ingredients. Initiated April 1, 2025. Status: A proposed 100 percent tariff on certain imports was paused to negotiate trade agreements with individual producing countries.
• Processed Critical Minerals and Derivative Products. Initiated April 16, 2025. Status: A report found a national security threat, but Trump announced in January 2026 that there will be no immediate tariffs or quotas, opting for monitoring and negotiations.
• Medium-Duty and Heavy-Duty Trucks and Parts. Initiated April 22, 2025. Status: Tariffs of 25 percent on trucks and parts and 10 percent on buses took effect on November 1, 2025.
• Commercial Aircraft and Jet Engines. Initiated May 1, 2025. Status: Completed. Investigation concluded with no immediate tariffs imposed; Trump directed further discussions and negotiations earlier this month.
• Polysilicon and Its Derivatives. Initiated July 1, 2025. Status: Open and report overdue.
• Unmanned Aircraft Systems and Parts. Initiated July 1, 2025. Status: Open and report overdue.
• Wind Turbines. Initiated August 13, 2025. Status: Open and report overdue.
• Medical Supplies and Devices. Initiated September 2, 2025. Status: Open and report overdue.
• Robotics and Industrial Machinery. Initiated September 2, 2025. Status: Open and report overdue.
• Anthracite Coal. Initiated June 29, 2026. Status: Ongoing.

While some of these (kitchen cabinets) don’t pass the laugh test and some (trucks and coal) are debatable, for most of them a national security nexus can likely be established, which is why opponents are gloomy about the prospects of litigation success. At the same time, some of them (aircraft, pharmaceuticals, and minerals) have not led to immediate tariffs, suggesting that the administration has begun to recognize that tariffs are not a universally useful tool. In those cases, tariffs would have made domestic industries that rely on foreign inputs less competitive and raised U.S. prices. Some of the still-open investigations show the same dilemma—the U.S. dependency on foreign sources is clear and poses a security threat, but imposing tariffs would only make things worse by making it harder for the domestic competitors to grow and thrive. That the administration appears to be recognizing that is a sign that U.S. trade policy may be becoming more strategic and less tactical.

Author’s note: I retired from CSIS on March 29, 2026. I plan to continue writing this column and participating in The Trade Guys podcast, so please continue to read and listen. However, my CSIS email address will no longer be working, so if readers or podcast listeners want to contact me directly, they should do so at [email protected].

William A. Reinsch is a senior adviser (non-resident) and Scholl Chair emeritus with the Economics Program and Scholl Chair at the Center for Strategic and International Studies in Washington, D.C.