U.S. EXTRA TARIFFS UNDER SECTION 232 INVESTIGATIONS

Spring 2025 - Aluisio de Lima-Campos

May 23, 2025

In addition to the International Emergency Economic Powers Act (IEEPA) of 1977, already covered in this edition, which implements the reciprocal tariffs by Executive Order without bureaucratic delays, the Trump Administration’s tariffs arsenal includes actions under Section 232 of the Trade Expansion Act of 1962, for which an investigative process is required. Investigations can be petitioned to the Department of Commerce’s Bureau of Industry and Security (BIS), which will investigate the effects of imports on national security. At the end of 270 days, the BIS must deliver a report with recommendations to the White House. The original extra tariffs on steel and aluminum implemented in 2018, during Trump’s first term, were the result of these investigations. In the case of automobiles, the investigation was done in 2018. Its report, issued in 2019, recommended a 25% tariff on imports, which was

A close up of scrabble tiles spelling the word usa, tarifs — Photo by Markus Winkler on Unsplash

only implemented in 2025.

Between March 10 and May 1, seven investigations have been started by BIS. This number of ongoing investigations in such a short period of time is unprecedented. And, given the potential of some or all the imports investigated to become subject to some sort of restrictive trade measure within the next 9 months, it is concerning. The list below includes the product’s name, links to the respective Federal Register Notices and investigation number.

1. Copper – Initiated March 10, 2025