Current and Forthcoming Section 232 Actions by the Trump Administration

Section 232 of the Trade Expansion Act of 1962 (“Section 232”) authorizes the President to “adjust” imports—including through application of tariffs, quotas, tariff rate quotas, and license fees—where the Department of Commerce (“Commerce”) determines imports threaten to impair U.S. national security. Since February 2025, President Trump has invoked Section 232 to impose or modify tariffs on U.S. imports across a range of sectors. These include actions on imports of steel, aluminum, and copper; automobiles and auto parts; timber, lumber, and wood products; trucks, truck parts, and buses; critical minerals; semiconductors; and pharmaceuticals. Potential actions by the Trump administration are pending in six ongoing Section 232 investigations, and new Section 232 investigations are rumored to be forthcoming. This alert provides an overview of the Section 232 actions taken by the second Trump administration as of April 2026 and also addresses upcoming and possible future Section 232 actions.

Since February 2025, the Trump administration has imposed or expanded tariffs under Section 232 across multiple sectors. These include U.S. imports of steel, aluminum, and copper, as well as associated derivatives (downstream products incorporating these metals); autos and auto parts; medium- and heavy-duty vehicles (“MHDVs”), MHDV parts (“MHDVPs”), and buses; timber, lumber, and certain wood products; semiconductors; and pharmaceuticals. With the exception of the tariffs on pharmaceuticals—which are scheduled to take effect in stages beginning in July 2026—these Section 232 tariffs are all currently in force.

In addition to imposing tariffs, the Trump administration has also launched international negotiations under Section 232 to address national security concerns regarding certain U.S. imports. For instance, in addition to imposing tariffs on a narrow set of advanced semiconductors, President Trump also directed Commerce and the U.S. Trade Representative (“USTR”) to pursue international negotiations to address national security concerns regarding U.S. imports of semiconductors, semiconductor manufacturing equipment, and their derivative products. Similarly, after the conclusion of the Section 232 investigation into processed critical minerals and their derivative products, the President deferred imposition of tariffs in favor of international negotiations, while leaving open the option of deploying other tools as needed in the future. An overview of the various Section 232 actions that have been taken by the Trump administration since February 2025 appears in the chart below.

Summary of Section 232 Actions

In addition, the Trump administration has initiated six Section 232 investigations that remain pending on a range of other products and sectors, as set out below. While the results of these investigations are expected in the coming weeks or months pursuant to deadlines set out in the statute, the President retains significant flexibility to announce actions that may effectively preserve his ability to impose trade measures at a later date, including by instructing U.S. agencies to pursue negotiations or conduct supplemental analyses. Where a determination is made that no national security threat exists or the President decides not to take action, it is possible no announcement regarding the outcome of the investigation will be made.

Media reports suggest that the administration is also considering initiating additional investigations into imports of large-scale batteries, cast iron and iron fittings, plastic piping, and industrial chemicals, as well as power grid and telecommunications equipment.

While the structures and frameworks for Section 232 duties differ significantly by sector, there are certain common themes across the various Section 232 actions taken under the second Trump administration. These recurring themes may be of particular importance to importers or companies operating in sectors that may be affected by Section 232 tariffs.

Shifting Tariff Landscape and Unpredictable Implementation Persist

Under several Section 232 tariffs currently in force, the President has repeatedly modified applicable tariff rates, revised implementation frameworks, or—in some cases—created new offset mechanisms or country-specific tariff reductions. All of these changes have given rise to a shifting tariff landscape, often accompanied by uncertainties regarding implementation plans.

Recent changes to Section 232 tariffs on metals (steel, aluminum, and copper) exemplify these challenges. For instance, in August 2025, the Trump administration added more than 400 downstream derivative products to the scope of tariffs on steel and aluminum imports. At the same time, importers faced significant uncertainty regarding implementation, particularly with respect to how applicable duties on metal derivatives should be calculated. Despite repeated requests for clarification made over the course of several months, no definitive guidance was forthcoming. Then, without prior notice, the administration announced in early April 2026 that it was overhauling Section 232 tariffs on aluminum, steel, and copper, fundamentally changing the structure and framework of these metal tariffs. These changes modified the scope of products subject to the tariffs, revised the applicable tariff rate structures, enacted significant amendments to the process for calculating metal tariffs due, and eliminated the derivative inclusion process that allowed domestic interested parties to request tariff scope expansions.

The Trump administration has also established and periodically adjusted a number of country-specific tariff rates affecting the application of Section 232 tariffs, reflecting deals negotiated with trade partners. Even while importers may welcome some of these adjustments, these changes—which in some instances have been significant—demonstrate that the Trump administration is willing to shift course in ways that create challenges for importers and businesses that rely on international supply chains.

Tariff Stacking Remains Nuanced and Complex

A key consideration for importers has been assessing how tariffs imposed under Section 232 may cumulate (or “stack”) with other tariffs that are already in effect or that may be imposed in the future. At present, all Section 232 tariffs continue to apply on top of tariffs currently in force on imports from China under Section 301 of the Trade Act of 1974 (“Section 301”). Beyond this general rule, tariff stacking quickly becomes a much more complicated exercise that must often be assessed on a sector-by-sector and country-by-country basis.

For instance, while most Section 232 tariffs stack on top of the “standard” tariff rates set out in Column 1 of Chapters 1 through 97 of the Harmonized Tariff Schedule of the United States (“HTSUS”), this is not always the case. The Section 232 tariffs of 100 percent on pharmaceutical products that take effect in July 2026 will be inclusive of duties imposed under Column 1 of the HTSUS. In addition, certain country-specific rates established under various Section 232 actions—particularly country-specific rates for the EU, Japan, Korea, Switzerland, and Liechtenstein—may also be inclusive of Column 1 rates.

At present, Section 232 duties generally will not stack with the 10 percent global tariffs imposed under Section 122 of the Trade Act of 1974 (“Section 122”). Importantly, however, prior to April 6, 2026, Section 122 tariffs may have applied to the non-metal content of certain derivative products subject to the Section 232 metal tariffs. In addition, while Section 122 tariffs are scheduled to expire on July 24, 2026, the administration has indicated that it intends to impose additional tariffs under Section 301 that may take effect around the same time. It is not yet clear whether any new Section 301 duties will stack with Section 232 tariffs.

In short, the tariff stacking rules have changed significantly over the past year and remain nuanced and complex. It is likely that stacking rules will continue to change as additional Section 232 actions are rolled out and new tariffs are announced under Section 301 or other authorities. Importers and companies that rely on international supply chains should thus pay close attention to developments in tariff stacking rules.

Covington’s trade lawyers have been advising a wide range of clients with regard to recent tariff actions, including those imposed under Section 232. Covington can assist with related customs and supply chain questions, as well as with assessing exposure to potential foreign retaliatory trade actions and evaluating options for navigating such measures. If you have any questions concerning this alert, please contact the following members of our Trade Policy practice.

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If you have any questions concerning the material discussed in this client alert, please contact the members of our Trade Policy practice.