Trump administration initiates Section 232 investigation of anthracite coal imports

On July 2, 2026, the US Department of Commerce's Bureau of Industry and Security (BIS) announced the initiation of an investigation into the US national security implications of importing anthracite coal, with a particular focus on metallurgical coal used in steel production.¹ The notice indicates that BIS is specifically considering the imposition of tariffs as a potential outcome of the investigation. BIS is conducting the investigation under Section 232 of the Trade Expansion Act of 1962, which authorizes the president to restrict imports of products that are found to threaten to impair US national security.

A Section 232 investigation, from initiation to presidential action, may span up to 360 days, which would place the latest possible deadline in late June 2027. Consistent with other recent Section 232 investigations, the BIS notice provides a notably short period for public comments and does not indicate any intention to hold public hearings. Comments on the anthracite coal investigation are due by July 21, 2026.

About Section 232

Section 232 of the Trade Expansion Act of 1962² (Section 232) authorizes the president to take action, including imposing import restrictions and entering into negotiations, to adjust imports of products that are found to threaten US national security. Any presidential action under Section 232 must be preceded by a Department of Commerce investigation into the national security implications of imports in the relevant sector.

Unlike other US trade remedy regimes (including safeguards, Section 301, antidumping duties, and countervailing duties), Section 232 does not require evidence of a market access violation or economic injury as a condition for imposing measures.

Scope of the investigation

The investigation targets anthracite coal, with a focus on the most energy-dense high rank forms that BIS defines as "characterized by its high carbon content (86-97 percent), low volatile matter, and superior heating value" and classifies under HTSUS 2701.11.0000 (anthracite coal, not agglomerated) and HTSUS 2701.12.0010 (metallurgical bituminous coal, not agglomerated). Other forms of bituminous and sub-bituminous coal and briquettes, as well as lignite, coke and coal gas, do not appear to fall within the stated scope of the investigation.

The notice highlights the use of the covered coal products in steelmaking, describing anthracite coal as "critical materials for domestic steel production and industrial processes[.]" BIS further explains that "steelmakers use anthracite coal for electric arc furnace (EAF) steelmaking due to its purity and role as a foaming agent and charge ingredient, supporting mission-critical operations across industrial, defense and infrastructure sectors."

In 2025, US imports included:

• $37.3 million of anthracite coal, of which $23.9 million originated in Peru, with most of the remaining volume supplied by the United Kingdom and China.
• $85.7 million of metallurgical bituminous coal, sourced almost entirely from Canada.

The covered coal products are exempt from current tariffs

Coal, including the forms covered by this investigation, is exempt from the 10% global Section 122 tariff. Coal was also excluded from the global "reciprocal" tariffs previously imposed under the International Emergency Economic Powers Act (IEEPA), and the Office of the United States Trade Representative (USTR) has proposed to exclude coal from the 10% or 12.5% forced labor Section 301 tariff applicable on the 60 largest US trade partners.

Approximate timeline for the Section 232 investigation

Key dates for the investigation and public comment process include:

• June 29, 2026: Investigation initiated
• July 21, 2026: Deadline to submit written comments (14 days after publication of the Federal Register notice)
• March 26, 2027: Approximate deadline for BIS to transmit its report to the president (270 days after initiation)
• June 24, 2027: Latest date by which the president is expected to announce any responsive action

Under Section 232, BIS has 270 days from initiation to complete the investigation and provide its findings and policy recommendations to the president. If BIS concludes that the covered imports threaten to impair national security, the president then has 90 days from receipt of the report to decide whether to concur and whether to exercise statutory authority to adjust imports. Any such action must be implemented no later than 15 days after the presidential determination. Alternatively, the president may direct the US government to pursue agreements with other countries to address the national security concerns, which would extend the implementation period by 180 days.

Recent practice under the Trump administration has introduced uncertainty into these timelines. For example, on April 2, 2026, President Trump issued a proclamation imposing tariffs under the Section 232 investigation into imports of pharmaceuticals and pharmaceutical ingredients 366 days after the investigation's initiation, beyond the 360-day timeline. Since then, the statutory deadlines in the Section 232 investigations on commercial aircraft and engines, polysilicon, and unmanned aircraft systems have all elapsed without public action or comment from the Trump administration, underscoring the potential for delays in the anthracite coal investigation.

Opportunity for public comments

Interested stakeholders may submit comments through the public docket at Regulations.gov.³ Comments are due by July 21, 2026, and the notice provides detailed instructions on submission. Participation in the comment process can influence the outcome of the investigation and encourage regulators to further clarify proposed actions. The BIS notice does not indicate that public hearings will be held, and such hearings are discretionary in Section 232 investigations.

BIS is particularly interested in comments that address the regulatory criteria for assessing the impact of imports on national security. Relevant comments could address, among other issues,

• Current and projected demand for anthracite coal;
• Ability of domestic production to meet that demand;
• Role and reliability of foreign supply chains;
• Concentration of US imports from a limited number of source countries and related vulnerabilities;
• Effects of foreign practices on the competitiveness of US anthracite producers;
• Economic impact of artificially depressed prices;
• Risk of export restrictions by foreign suppliers;
• Feasibility of expanding domestic production and capacity;
• Impact of existing trade policies on domestic output and the relationship between anthracite use and US manufacturing employment;
• Potential for foreign control or leverage over the anthracite coal supply chain;
• Future role of anthracite coal in the production of items essential to national security; and
• Other factors relevant to the statutory and regulatory analysis.

_{1 BIS "Notice of Request for Public Comments on Section 232 National Security Investigation of Anthracite Coal," unpublished Federal Register notice (scheduled to be published July 7, 2026).
2 19 U.S.C. §1862 and 15 C.F.R. part 705.
3 The regulations.gov docket ID for this notice is BIS-2026-0298. Please reference XRIN 0694-XC165 in all submissions.}

For further information regarding this report or international trade matters, please contact any of the partners or senior attorneys listed below from White & Case’s Global International Trade Practice.

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_{This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.}

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