In July, the Trump administration initiated two new investigations under Section 232 of the Trade Expansion Act of 1962 (Section 232) and one new investigation under Section 301 of the Trade Act of 1974 (Section 301). For context, Section 232 is the provision under which the current 50% tariffs on steel and aluminum are implemented, and a Section 301 investigation from the first Trump administration led to a 25% tariff on imports of most Chinese-origin goods.
Section 232 Investigations of Polysilicon and Unmanned Aircraft Systems
On July 16, the Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register Notice announcing the initiation of a Section 232 investigation of imports of polysilicon and polysilicon derivatives. Section 232 investigations focus on national security impacts of imports, and polysilicon is a key component in solar panels and semiconductors, which are both of strategic importance to the U.S. government.
That same day, BIS also published a Federal Register Notice announcing a separate Section 232 investigation of imports of unmanned aircraft systems (UAS) and related parts and components. UAS are like unmanned aerial vehicles (UAV), or drones, but may also encompass systems related to the UAV, like ground control and communications systems. The UAS investigation follows President Trump's June 6, 2025, executive order on Unleashing American Drone Dominance.
BIS initiated both new Section 232 investigations on July 1, 2025, and public comments for the investigations are due by August 6, 2025.
Other Section 232 Investigation Updates
On July 9, President Trump announced on social media a forthcoming 50% tariff on copper pursuant to a Section 232 investigation into the national security impacts of copper imports. BIS initiated the copper investigation on March 10, 2025. According to President Trump, tariffs on copper imports will be implemented on August 1, 2025.
The second Trump administration has now opened nine investigations under Section 232. In addition to the polysilicon, UAS, and copper investigations, there are also open investigations into timber and lumber, semiconductors and semiconductor manufacturing equipment, pharmaceuticals and pharmaceutical ingredients, trucks, critical minerals, and commercial aircraft. In statements to the press, President Trump has hinted that he may also implement tariffs on semiconductors and pharmaceuticals as soon as August 1.
Section 301 Investigation of Brazil
On July 15, the U.S. Trade Representative (USTR) announced the commencement of a Section 301 investigation into Brazil's trade practices. Unlike Section 232 investigations, Section 301 investigations are not focused on national security impacts but instead are triggered by potentially unfair trade practices of U.S. trading partners. The Section 301 investigation of Brazil will focus on the following practices as outlined in the USTR's announcement:
- Digital trade and electronic payment services, including the potential undermining of U.S. companies' competitiveness in Brazil;
- Unfair, preferential tariff rates for certain trade partners;
- Failure to enforce anti-corruption measures;
- Intellectual property protection;
- Increased tariffs on U.S. ethanol exports; and
- Brazil's apparent failure to "effectively enforce laws and regulations designed to stop illegal deforestation, thereby undermining the competitiveness of U.S. producers of timber and agricultural products."
The comment period for the Section 301 investigation into Brazil's trade practices begins on July 17 and runs through August 18, 2025.
The pace of tariff actions has not slowed nearly six months into the second Trump administration. If you are interested in submitting public comments in any of the above investigations or have questions about Section 232 or Section 301 investigations generally, feel free to reach out to the attorneys at Torres Trade Law.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
