Trump Administration Initiates Section 232 Investigation on Robotics and Industrial Machinery

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On September 24, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) announced the initiation of an investigation into the effects on US national security of imports of robotics and industrial machinery.1 The investigation could result in the imposition of tariffs or other import restrictions by Spring 2026. BIS is conducting the investigation under Section 232 of the Trade Expansion Act of 1962 (Section 232), a law that empowers the president to restrict imports of products that threaten to impair national security.2 Section 232 investigations can take up to 270 days to complete (setting the latest date for completion in May 2026), but the Trump administration has signaled it intends to move faster. Like other recent Section 232 investigations, the new initiation notice provides a short timespan for public comments and does not reference plans to hold a public hearing.

Initiation notice and scope

The investigation notice on industrial robots and machinery describes the investigation as seeking to, "determine the effects on the national security of imports of robotics and industrial machinery." The notice elaborates on what is within the scope of each of the categories, stating that, "this equipment spans [computer numerical control (CNC)] machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. It also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding, and handling work pieces. Application-specific specialty metalworking equipment used to treat, form, or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, [electrical discharge machining (EDM)] machinery, and laser and water-cutting tools and machinery is also included. The scope of this investigation does not include unmanned aircraft systems, which are covered by a different section 232 investigation[.]"3

Opportunity for public comments

Interested stakeholders may submit comments through the public docket at Regulations.gov. Comments are due by October 17, 2025. The notice provides additional instructions on how to participate and submit comments. BIS will consider and respond to public comments as it conducts the investigation. Participating in the public comment process can help shape the outcome of the investigation and prompt regulators to further clarify actions. The BIS notice does not mention public hearings (public hearings are discretionary for Section 232 investigations).

The notice highlights that BIS is especially interested in comments that directly address the regulatory criteria for determining the effects of imports on national security. The notice states that comments addressing the regulatory criteria could include answering questions related to:

(i)  the current, projected, and optimal demand for robotics and industrial machinery, and their parts and components in the United States;

(ii)  the extent to which domestic production of robotics and industrial machinery, and their parts and components can meet domestic demand;

(iii)  the role of foreign supply chains, particularly of major exporters, in meeting United States demand for robotics and industrial machinery, and their parts and components;

(iv)  the concentration of US imports of robotics and industrial machinery, and their parts and components from a small number of suppliers or foreign nations and the associated risks;

(v)  the impact of foreign government subsidies and predatory trade practices on the competitiveness of the robotics and industrial machinery, and their parts and components, in the United States;

(vi)  the economic impact of artificially suppressed prices of robotics and industrial machinery, and their parts and components due to foreign unfair trade practices and state-sponsored overproduction;

(vii)  the potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of robotics and industrial machinery, and their parts and components;

(viii)  the feasibility of increasing domestic capacity for robotics and industrial machinery, and their parts and components to reduce import reliance;

(ix)  the impact of current trade policies on domestic production of robotics and industrial machinery, and their parts and components, and whether additional measures, including tariffs or quotas, are necessary to protect national security;

(x)  the impact of the use or lack of use of robotics and industrial machinery on US manufacturing employment;

(xi)  the potential for foreign control or exploitation of the robotics and industrial machinery supply chain;

(xii)  the ability of foreign persons to weaponize the capabilities or attributes of foreign-built robotics and industrial machinery, and their parts or components;

(xiii)  the future role of robotics and industrial machinery in the production of items essential to national security or in activities related to national security; and

(xiv)  any other relevant factors.

The Trump administration’s Section 232 investigations

The Trump administration's recent activities

The Section 232 investigation on robotics and industrial machinery is one of two investigations announced on September 24, the other being on, personal protective equipment, medical consumables, and medical equipment, including devices.4 The two announcements are the latest in a series of sector-specific tariff actions by the Trump administration. Since taking office on January 20, 2025, President Trump has expanded the Section 232 tariffs on steel and aluminum; revived a Section 232 investigation from his first term to impose tariffs on imports of passenger vehicles, light trucks, and certain automotive parts; and imposed new tariffs on semi-finished copper and intensive copper derivative products. Other ongoing Section 232 investigations target imports of timber, lumber, and wood products; semiconductors and semiconductor manufacturing equipment; pharmaceuticals and pharmaceutical ingredients; processed critical minerals and downstream products; trucks and truck parts; commercial aircraft and jet engines and their parts; wind turbines and their parts and components; and unmanned aircraft systems (UAS) and their parts and components.

Though the Section 232 process allows BIS up to 270 days to complete the investigation and another 90 days for the president to make a policy determination, the Trump administration has moved unusually quickly with its new investigations. The first new Section 232 action completed in 2025 (addressing imports of copper) saw tariffs implemented 144 days after BIS initiated the investigation. President Trump and senior administration officials have repeatedly stated that the outcomes of the other ongoing investigations are imminent, though they have provided few specific details.

President Trump's two-track tariff strategy

In recent months, the Trump administration has appeared to move towards a two-track tariff strategy, imposing (i) "baseline" and "reciprocal" tariffs on most products from most countries under the International Emergency Economic Powers Act (IEEPA), apparently seeking to negotiate more favorable market access conditions in return for the lifting of the tariffs; and (ii) Section 232 tariffs on imports associated with industries the Trump administration views as strategically important. Unlike most other tariffs President Trump has imposed, the IEEPA "baseline" / "reciprocal" tariffs and the Section 232 tariffs do not "stack" on top of each other. Instead, products affected by Section 232 tariffs are exempt from the IEEPA "baseline" / "reciprocal" tariffs.

The Trump administration's recent trade deal framework agreements with US allies include commitments to moderating some of the active and potential future Section 232 tariff actions, in addition to reductions to the IEEPA "baseline" / "reciprocal" tariffs:

  • The agreements with the United Kingdom, European Union, and Japan include reduced automotive Section 232 tariff rates or alternative tariff-rate quotas.
  • The agreement with the UK includes a commitment to negotiating preferential treatment for UK goods subject to the ongoing Section 232 investigation on pharmaceuticals and pharmaceutical ingredients, as well as a general commitment to negotiate preferential treatment for the UK in any future Section 232 tariff actions.
  • The agreement with the EU commits to a 15% maximum tariff for any potential Section 232 tariffs on timber, lumber, and wood products; pharmaceuticals and pharmaceutical ingredients; and semiconductors and semiconductor manufacturing equipment.
  • The agreement with Japan includes a commitment to providing imports from Japan with treatment that is no less favorable than that provided to any other trade partner in the potential Section 232 tariff actions on pharmaceuticals and pharmaceutical ingredients as well as semiconductors and semiconductor manufacturing equipment.

The other ongoing Section 232 investigations, including the two announced on September 25, are not specifically referenced in any of the framework agreements. US trade partners, including the UK, EU, and Japan, are unlikely to receive any benefits under these investigations or ensuing trade measures without further negotiations.

1 "Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Robotics and Industrial Machinery," 90 FR 46382 (September 26, 2025).
2 See 19 U.S.C. §1862; and 15 C.F.R. part 705. More information on BIS' ongoing Section 232 investigations and past reports can be found on the BIS website.
3 See "Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Unmanned Aircraft Systems (UAS) and Their Parts and Components," 90 FR 31958 (July 16, 2025).
4 "Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices," 90 FR 46383 (September 26, 2025).

We provide below a list of partners and senior attorneys within the Global International Trade Practice of White & Case. Please contact any of them with questions about this report or other trade issues.

 

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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.

© 2025 White & Case LLP

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Ian Saccomanno
Ian Saccomanno
Senior Trade Analyst|Washington, DC
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