Section 232 Tariffs Threatened on Drones, Solar Panel Components

The Bureau of Industry and Security is accepting input no later than Aug. 6 on two new Section 232 investigations to determine the effects on national security of imports of (1) unmanned aircraft systems and their parts and components and (2) polysilicon and its derivatives. These investigations could result in the imposition of additional tariffs on imports of these products.

Interested parties are invited to submit written comments, data, analyses, or other information pertinent to these investigations. Among other things, BIS is interested in the following.

– current and projected demand for covered goods in the U.S.

– the extent to which domestic production can meet that demand

– the role of foreign supply chains, particularly major exporters, in meeting that demand

– the concentration of U.S. imports from a small number of suppliers or foreign nations and the associated risks

– the impact of foreign government subsidies and predatory trade practices on U.S. industry competitiveness

– the economic impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overproduction

– the potential for foreign nations and companies to weaponize (1) their control over supplies of covered products and/or (2) the capabilities or attributes of foreign-built covered products

– the feasibility of increasing domestic capacity to reduce import reliance

– the impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security

ST&R offers a three-pronged approach to avoiding, mitigating, and/or recovering import tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.