More Critical Minerals Could be Subject to Section 232 Tariffs

The Department of the Interior is inviting comments before Sept. 25 on its 2025 draft list of critical minerals, imports of which could become subject to Section 232 tariffs depending on the outcome of an ongoing investigation.

The minerals on this list (1) are essential to U.S. economic or national security, (2) have supply chains vulnerable to disruption, and (3) serve an essential function in the manufacturing of a product whose absence would have significant consequences for U.S. economic or national security (e.g., applications related to energy technology, defense, currency, agriculture, consumer electronics, and healthcare).

This list must be updated every three years and DOI is now proposing to remove arsenic and tellurium and add copper, lead, potash, rhenium, silicon, and silver. DOI will also consider adding uranium and metallurgical coal and invites public comment on whether other minerals should be added as well.

Further, DOI is not proposing to include the following minerals on the 2025 list but may still ultimately include them: arsenic, cadmium, feldspar, gold, helium, iron ore, mica, molybdenum, phosphates, selenium, strontium, and tellurium.

In April 2025 President Trump directed the Bureau of Industry and Security to initiate a Section 232 investigation of critical minerals and their derivative products, with a final report due by mid-October. Recommendations for action could include the imposition of tariffs as well as other import restrictions; safeguards to avoid circumvention and weakening of any section 232 measures; policies to incentivize domestic production, processing, and recycling; and any additional measures that may be warranted to mitigate national security risks. A White House fact sheet noted that any Section 232 tariffs imposed “would take the place of the current reciprocal tariff rate” on covered goods.