This Trade Alert summarizes various Section 232 of the Trade Expansion Act of 1962 investigations initiated by the U.S., as well as findings of the U.S. Section 301 of the Trade Act of 1974 investigation into China’s maritime shipbuilding.

Critical Minerals Section 232 Investigation

Date Initiated: April 15, 2025
Report Due: Interim within 90 days, final by October 12, 2025
Focus: Broad coverage of minerals from ore to end-product (e.g., batteries, EVs, chips)

Summary:

• On April 15, President Trump signed the Ensuring National Security and Economic Resilience Through Section 232 Actions on Processed Critical Minerals and Derivative Products Executive Order (“EO”). 
• This EO directs the U.S. Department of Commerce (“DOC”) to initiate a Section 232 investigation to determine whether imports of processed critical minerals and their derivative products threaten to impair national security. The EO defines the minerals identified by the 2022 U.S. Geological Survey, along with uranium and rare earth elements identified by the Department of Energy’s April 2020 report.
• The EO also applies broad definitions of “processed critical minerals” and “Derivative Products” to include critical minerals that have undergone the activities that occur after critical mineral ore is extracted from a mine up through its conversion into a metal, metal powder, or a master alloy and all goods that incorporate processed critical minerals as inputs, respectively. These goods include semi-finished goods (such as semiconductor wafers, anodes, and cathodes) as well as final products (such as permanent magnets, motors, electric vehicles, batteries, smartphones, microprocessors, radar systems, wind turbines and their components, and advanced optical devices). This is a wide-ranging scope of final goods.
• The EO does not mention whether this investigation is open to public comment, but it is expected, as all other Section 232 investigations have been subject to public comment. The EO calls for the Secretary of Commerce to submit, within 90 days, a draft interim report for review and comment among the interagency for their review and comment within 15 days. Then, Commerce is to submit a final report and recommendations to the President within 180 days of the investigation’s commencement (i.e., by October 12).
• If the DOC finds U.S. national security concerns during this investigation, tariffs on critical minerals, processed critical minerals, and derivative products would be likely.
• USGS Critical Minerals List: aluminum, antimony, arsenic, barite, beryllium, bismuth, cerium, cesium, chromium, cobalt, dysprosium, erbium, europium, fluorspar, gadolinium, gallium, germanium, graphite, hafnium, holmium, indium, iridium, lanthanum, lithium, lutetium, magnesium, manganese, neodymium, nickel, niobium, palladium, platinum, praseodymium, rhodium, rubidium, ruthenium, samarium, scandium, tantalum, tellurium, terbium, thulium, tin, titanium, tungsten, uranium, vanadium, ytterbium, yttrium, zinc, and zirconium.

Semiconductor Section 232 Investigation

Date Initiated: April 13, 2025
Public Comment Deadline: May 7, 2025
Focus: Semiconductor and equipment imports & domestic production shortfalls

Summary:

• On April 13, the DOC announced its Section 232 investigation and the impact on U.S. national security due to imports of semiconductors and semiconductor manufacturing equipment (SME) and their derivative products.
• The Federal Register notice provides until May 7 to provide comment and requests comments on a variety of topics, including: the current and projected demand for semiconductors (including as embedded in downstream products) and SME in the U.S.; the extent to which domestic production of semiconductors can or is expected to be able to meet domestic demand; the role of foreign fabrication and assembly, test and packaging facilities in meeting U.S. semiconductors demand; the concentration of U.S. semiconductors imports (including as embedded in downstream products); the potential for export restrictions by foreign nations; the feasibility of increasing domestic semiconductors capacity; and any other relevant factors.
• If the DOC finds U.S. national security concerns during this investigation, tariffs on semiconductors and semiconductor manufacturing equipment (SME), and their derivative products would be likely.

Pharmaceuticals Section 232 Investigation

Date Initiated: April 13, 2025
Public Comment Deadline: May 7, 2025
Focus: Imports of APIs, medical countermeasures, and pharma inputs

Summary:

• On April 13, the DOC announced its Section 232 investigation into the impact on U.S. national security due to imports of pharmaceuticals, pharmaceutical ingredients, medical countermeasures, critical inputs (e.g., active pharmaceutical ingredients), and derivative products of those items. 
• The Federal Register notice provides until May 7 to provide comment and requests comments on a variety of topics, including: the extent to which domestic production of pharmaceuticals and pharmaceutical ingredients can meet domestic demand; the role of foreign supply chains, particularly of major exporters, in meeting United States demand for pharmaceuticals and pharmaceutical ingredients; and the feasibility of increasing domestic capacity for pharmaceuticals and pharmaceutical ingredients to reduce import reliance.
• If the DOC finds U.S. national security concerns during this investigation, tariffs on pharmaceuticals, pharmaceutical ingredients, medical countermeasures, critical inputs (e.g., active pharmaceutical ingredients), and derivative products of those items would be likely.  

Copper Section 232 Investigation

Date Initiated: February 25, 2025
DOC Report Due: Within 270 days (~Nov 2025)
Focus: National security risk from copper import dependence

Summary:

On February 25, President Trump signed an executive order initiating a Section 232 investigation to assess whether copper imports pose a threat to U.S. national security. The DOC is evaluating and is tasked with producing a report with findings and recommendations, potentially including tariffs or incentives to boost domestic production, which will be submitted to the President within 270 days.

Chinese Shipbuilding and Maritime Section 301 Investigation

Date Announced: April 18, 2025
Focus: China’s dominance in shipbuilding/logistics deemed unfair
Tariffs Proposed: Up to 100% on cranes and cargo equipment

Summary:

• On April 18, the U.S. Trade Representative (“USTR”) determined that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens or restricts U.S. commerce. This will enable action under Section 301 by the USTR.
• As a result, the USTR is adopting phase-in fees on: (1) Chinese vessel operators and owners; (2) operators of Chinese-built vessels; (3) vessel operators of foreign vehicle carriers. These fees are subject to a six-month delay.
• The USTR is also proposing tariffs of up to 100% on certain ship-to-shore cranes “on a non-discriminatory basis” (i.e., regardless of country of origin) and other cargo handling equipment of China.