Status of Section 232 Actions by the Trump Administration

Since taking office in January, President Trump has taken a number of actions under Section 232 of the Trade Expansion Act of 1962 (“Section 232”), a statute that 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. To date, President Trump has invoked Section 232 to impose or modify tariffs on U.S. imports of steel and aluminum, as well as imports of autos and auto parts. The Trump administration has also initiated nine other Section 232 investigations affecting several other sectors since January, and the President has publicly announced that new Section 232 tariffs will be imposed on copper imports effective August 1, with additional Section 232 tariff announcements likely in the coming weeks. This alert provides an overview of the Section 232 actions taken by the Trump administration since January and potential timelines for imposition of future Section 232 tariffs on a range of imports.

At present, Section 232 tariffs are in place on U.S. imports of steel, aluminum, autos, and auto parts. In the case of steel and aluminum, Section 232 tariffs also currently apply to many so-called “derivative” products that incorporate steel and aluminum.

Steel and Aluminum

As described in our previous alert, President Trump issued two proclamations in February modifying existing Section 232 tariffs on steel and aluminum imports in a manner that broadened coverage or raised rates. At the same time, the President removed all previous country exemptions from such tariffs and terminated the process for parties to seek product-specific exclusions from the tariffs. As a result, effective March 12, 2025, a tariff of 25% generally applied to most products covered by the Section 232 action on steel and aluminum.[1]

Since March, the Trump administration has taken the following additional actions with respect to the Section 232 tariffs on steel and aluminum:

• Further increasing Section 232 tariffs on steel and aluminum products and derivatives to 50%, effective June 4;
• Limiting application of these Section 232 duties, such that the 50% tariffs apply only to the steel or aluminum content of subject products, while reciprocal tariffs apply to all non-steel or non-aluminum content of those products;
• Creating an exception imposing a lower tariff of 25% on subject imports of the United Kingdom (“UK”) while specifics relating to steel and aluminum in the U.S. trade agreement with the UK are finalized; and
• Establishing a new “tariff inclusion process,” through which requests may be submitted to Commerce three times each year to include additional steel and aluminum products as derivatives subject to Section 232 tariffs.[2]

Autos and Auto Parts

On March 26, the President issued a Proclamation imposing a tariff of 25% on imports of automobiles effective April 3, with a tariff of 25% also on imports of auto parts effective May 3. These actions rested on a Section 232 investigation initiated in 2018, during President Trump’s first term. That investigation—which concluded in May 2019—determined that imports of auto and auto parts constituted a national security threat, though President Trump declined to impose any tariffs at that time. Instead, he directed the U.S. Trade Representative to negotiate agreements to address the U.S. national security concerns. In his March proclamation, President Trump announced his determination that these negotiations were unsuccessful.

On April 29, President Trump modified the Section 232 tariffs on auto parts by creating an offset for U.S. automobile manufacturers that meet certain requirements. The modification allows U.S. manufacturers to claim and use a credit to offset tariffs owed on imports of auto parts, which is tied to the aggregate sales value of the manufacturer’s vehicles undergoing final assembly in the United States.

In late June 2025, Commerce also announced a new “tariff inclusion process” through which requests could be made for adding new automobile parts to the list of articles subject to the 25% Section 232 tariffs.

In addition to the Section 232 actions described above, the Trump administration has also initiated nine Section 232 investigations on a range of other products and sectors, including copper, lumber, pharmaceuticals, semiconductors, and critical minerals, among others. The Trump administration has repeatedly suggested it is seeking to expedite these investigations, and intends to conclude them much more quickly than the 270 days permitted under the statute. In line with this expedited approach, Commerce set short deadlines of approximately three weeks for submission of written comments in several investigations.

The scope of the pending Section 232 investigations is very broad, as they cover not only articles that are the focus of the investigation, but also “derivative” products that may incorporate such articles or inputs used to make those products. In the case of semiconductors, the investigation could potentially result in tariffs not only on semiconductors, but also on a wide range of electronics that incorporate such chips. Similarly broad tariffs may also result from the investigations on copper and critical minerals, which are components in a wide range of downstream products.

To date, no Presidential proclamations or Federal Register notices have been issued announcing the results of the nine Section 232 investigations initiated by the second Trump administration. President Trump and senior U.S. officials have nonetheless made several statements about forthcoming Section 232 tariffs. For instance, President Trump announced on July 8 that he would impose a 50% tariff on copper imports, confirming in a July 9 Truth Social post that the tariff would be effective August 1. President Trump has also suggested that Section 232 actions on pharmaceuticals may be imposed around the same time, and that tariffs on pharmaceuticals could reach as high as 200% over a 12- to 18-month period. Recent announcements regarding trade deals concluded by the Trump administration also indicate certain of those deals may also address how existing and future Section 232 tariffs will apply to imports from certain U.S. trading partners, including the UK and the EU.

Little else is currently known about the investigations, and no information has been made available regarding the specific products that will be covered by forthcoming Section 232 tariffs. It is also unclear if Commerce’s reports or conclusions in any of the pending Section 232 investigations will ultimately be made public. President Trump routinely declined to make such reports public during his first term, though these documents were later published by the Biden administration. Below is a summary of the current status of pending Section 232 investigations initiated under the second Trump administration:

Stacking of Section 232 Duties with Other Tariffs

While initial guidance from the Trump administration provided that Section 232 tariffs would not apply simultaneously (or “stack”) on top of certain other types of tariffs—such as reciprocal or border security tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”)—recent changes to these rules have rendered the stacking question more complex. Moreover, as additional Section 232 tariffs are announced, further changes to the applicable tariff stacking rules are likely.

At present, Section 232 tariffs apply on top of certain existing tariffs, such as Section 301 tariffs on China and most-favored nation (“MFN”) rates set out in Chapters 1 through 97 of the Harmonized Tariff Schedule of the United States. However, where an import is subject to one type of Section 232 tariff, other Section 232 tariffs generally will not apply.

Given the possibility that the stacking rules will change as new Section 232 actions are imposed, importers and companies that rely on international supply chains should pay close attention to any modification to tariff stacking rules in the future.

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.