Tariffs, quotas, or other restrictions on a wide range of imported steel products could be imposed in a matter of months as a result of the Trump administration’s latest trade enforcement effort.

The Department of Commerce has self-initiated an investigation under section 232 of the Trade Expansion Act of 1962 to determine whether imports of foreign-made steel are harming U.S. national security. A DOC fact sheet explains that “a robust and healthy domestic steel production industry is necessary for national security,” including the production of armor, ships, and aircraft, which could be accelerated under the Trump administration’s planned military buildup. However, the fact sheet adds, U.S. steelmakers have “struggled in recent years, raising concerns about the industry’s ability to support national security needs.” The investigation will therefore consider production and capacity, workforce, investment, research and development, and other factors to determine whether steel is being imported in such quantities or under such circumstances as to threaten or impair U.S. national security. 

In an April 20 memorandum President Trump directed the DOC to expedite this investigation. Under the law the department has up to 270 days to conclude a section 232 investigation and submit its report and recommendations to the president. However, Trump reportedly said he anticipates results within 30 to 50 days. The DOC said the probe will include a formal request for public comment, to be published in the Federal Register, followed by a public hearing.

If the DOC finds that excessive foreign steel imports are a threat to U.S. national security, and the president concurs, the president has the authority to adjust imports, including through the use of tariffs and quotas. Commerce Secretary Wilbur Ross said any such actions could affect “a very wide range of steel products and a very wide range of countries.” Any import adjustments, or any other non-trade-related actions the president may elect to take, would be imposed within 15 days of the president’s determination to act.

For more information on this section 232 investigation and how it may affect your business, please contact Kristen Smith at (202) 730-4965, Mark Ludwikowski at (202) 730-4967, or David Craven at (312) 279-2844.

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Kristen S. Smith
Member, Trade Remedies Practice Group Leader

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