On September 26, 2025, the Secretary of Commerce published a request for public comments relating to two national security investigations initiated on September 2, 2025, under Section 232 of the Trade Expansion Act of 1962.
The first investigation covers the national security implications of imports of robotics and industrial machinery, and the second covers the national security implications of imports of personal protective equipment (PPE), medical consumables, and medical equipment, including devices.
Comments on both investigations are due Friday, October 17, 2025.
Impact of Section 232 investigations
Section 232 of the Expansion Act of 1962 enables the president to impose tariffs or quotas on imports of certain products that are determined to threaten U.S. national security. The Trump administration has relied on the statute to impose numerous tariffs on a host of industries, such as 50% tariffs on imports of steel, aluminum, and copper; 25% tariffs on imports of automobiles and automobile parts; 15-25% tariffs on softwood timber and lumber, upholstered wooden furniture, kitchen cabinets, and vanities with potential increases to these rates in 2026.
The tariffs, which are not timebound, apply to all imports from all countries with limited or no exceptions. For instance, goods specially designed for handicapped persons are currently excluded from both Section 232 and IEEPA tariffs. It is unclear whether the exclusion will continue to apply following the conclusion of the current Section 232 investigation on medical devices.
Scope of products covered
Both investigations cover a broad range of products with implications for manufacturers across a range of industries.
Robotics and industrial machinery
The Section 232 investigation on robotics and industrial machinery includes programmable, computer-controlled mechanical systems such as CNC machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. It also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding, and handling work pieces. Further, specialty metalworking equipment such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery are also included.
According to some estimates the investigation will impact approximately half a trillion dollars in manufacturing equipment and inputs and would be the largest 232 investigation initiated to date.
PPE, medical consumables, and medical equipment including devices
PPE includes surgical masks, N95 respirators, gloves, gowns, and related medical parts and components.
Medical consumables refer to single-use or short-term-use items used for patient diagnosis, treatment, and prevention of conditions. Medical consumables include but are not limited to medical/surgical instruments (syringes, needles, infusion (IV) pumps, forceps, scalpels), medical/surgical supplies (intravenous (IV) bags, catheters, tracheostomy tubes, anesthesia equipment, gauze/bandages, sutures, diagnostic and laboratory reagents), and related medical parts and components.
Medical equipment includes carriages and wheelchairs, crutches, and hospital beds.
Medical devices includes devices used in the diagnosis, monitoring, or treatment of medical conditions such as pacemakers, insulin pumps, coronary stents, heart valves, hearing aids, robotic and non-robotic prosthetics, blood glucose monitors, orthopedic appliances, electromedical apparatus (e.g., computed tomography scanners, magnetic resonance imaging machines), electrosurgical apparatus, x-ray apparatus/other radiation equipment, respiratory machines ( e.g., ventilators, respirators, oxygen apparatus), and MRI machines.
Commerce is soliciting comments on several factors
For both investigations, the administration is soliciting comments which address specific factors as they relate to national security. Comments should include a discussion of the following:
- current, projected, and optimal demand for the products in the U.S. and extent to which domestic production of products can meet domestic demand;
- role of foreign supply chains, particularly of major exporters, in meeting U.S. demand and concentration of U.S. imports from a small number of suppliers or foreign nations and the associated risks;
- impact of foreign government subsidies, suppressed prices and export restrictions on U.S industry;
- feasibility of increasing domestic capacity, impact of current trade policies on domestic production, and the necessity of measures such as quotas or tariffs; and
- potential for foreign control or exploitation of supply chains and ability of foreign persons to weaponize their capabilities.
Next steps
The two Section 232 investigations have significant implications for both domestic manufacturers and importers. Husch Blackwell encourages clients who may be potentially affected by these investigations to contact their attorney and discuss whether comments should be filed on their behalf by the October 17, 2025 deadline.
Contact us
If you have questions regarding these Section 232 investigations, please contact Nithya Nagarajan, Cortney Morgan, Moushami Joshi, or your Husch Blackwell attorney.