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Section 232

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What the New US Trade Landscape Means for Businesses

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As US trade policy continues to evolve, businesses are increasingly confronting a reality in which tariffs are not simply temporary trade measures, but a recurring feature of the commercial landscape. This shift is prompting companies to incorporate tariff exposure into long-term decisions regarding sourcing, manufacturing, supply chain resilience and market access. At the same time, longstanding trade authorities and enforcement mechanisms are taking on renewed significance as policymakers use them to address economic, supply chain…

US: President Trump Imposes New Section 232 Measures on Polysilicon Products

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On August 6, 2026, President Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, establishing new import restrictions on polysilicon and a range of downstream products. This is the result of a process that started in July 2025. The Administration concluded that increased reliance on foreign sources for these materials raises concerns over the resiliency of supply chains that support semiconductor manufacturing, solar technologies, defense applications, and other strategically important…

United States: President Trump Tariffs on Patented Pharmaceuticals Under Section 232

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On April 2, 2026, President Trump issued a proclamation adjusting imports of patented pharmaceuticals and associated pharmaceutical ingredients, including active pharmaceutical ingredients (APIs). The action followed an investigation by the Secretary of Commerce under Section 232 of the Trade Expansion Act of 1962, which the proclamation states concluded that imports of patented pharmaceuticals and related inputs were being imported into the United States in such quantities and under such circumstances as to threaten to impair…

US: President Trump Issues Section 232 Proclamations on Semiconductors and Critical Minerals

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On January 14, 2026, President Trump issued two proclamations under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. § 1862), relating to imports of semiconductors and critical minerals (the “Semiconductor Proclamation” and “Critical Minerals Proclamation”, respectively). These proclamations—especially the Semiconductor Proclamation, which imposes an immediate 25% tariff on imports of certain semiconductors—will likely have significant impacts on U.S. trade in these sectors. Semiconductor Proclamation The Semiconductor Proclamation was issued based on the…

US: New BIS Guidance Expands Scope of Section 232 Steel and Aluminum Tariffs

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On August 15, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a draft Federal Register notice adding hundreds of tariff subheadings to the list of steel and aluminum derivative products subject to Section 232 tariffs imposed in June. The newly announced duties apply to the steel and aluminum content of derivative products that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August…

US: Preparing for US national security investigation of imports of pharmaceuticals and pharmaceutical ingredients

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In briefThe US Department of Commerce (“Commerce”) has initiated a Section 232 national security investigation into the imports of pharmaceuticals and pharmaceutical ingredients. This investigation aims to determine whether these imports threaten US national security. The scope of the investigation includes finished drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients (APIs), key starting materials, and derivative products of these items. Commerce may restrict imports of these products through tariffs, quotas, or other…