Articles Posted in Section 232

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In an April 2, 2026 Proclamation, the Trump administration made significant changes to the implementation of the existing tariffs on steel, copper, and aluminum products and derivative articles under Section 232 of the Trade Expansion Act (“Section 232”). Since June 2025, Section 232 duties on mixed metal and non-metal products have been calculated based on the value of the steel, aluminum or copper content within the article. This instruction to separate out metal versus non-metal content resulted in considerable confusion regarding the methodology to determine the price paid by the importer for steel or aluminum consistent with the principles of 19 U.S.C. 1401a.

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Last month, the U.S. Department of Justice (DOJ) announced the launch of a “cross-agency” Trade Fraud Task Force “to bring robust enforcement against importers and other parties who seek to defraud the United States.” According to DOJ, the Task Force will “augment the existing coordination mechanisms” within DOJ and leverage expertise from DOJ’s Civil and Criminal Divisions and the Department of Homeland Security (DHS) “to aggressively pursue enforcement actions against any parties who seek to evade tariffs and other duties, as well as smugglers who seek to import prohibited goods into the American economy.”

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The Trump administration has intensified its America First Trade Policy initiatives by announcing three new investigations under Section 232 of the Trade Expansion Act of 1962 by the Department of Commerce. As foreshadowed in the administration’s Day 1 Executive Order, last week Commerce announced the initiation of investigations into whether imports of pharmaceuticals, semiconductors and critical minerals threatened to impair national security. And on April 23, 2025, Commerce announced the initiation of a fourth Section 232 investigation into imports of trucks. These follow previously announced and ongoing investigations into copper and lumber, as well as existing section 232 duties on steel, aluminum and light passenger vehicles.

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