ARTICLE
23 July 2025

New Section 232 Investigations Into Polysilicon And Unmanned Aircraft Systems

The U.S. Department of Commerce initiated new Section 232 investigations to assess the national security implications of imports of polysilicon and unmanned aircraft systems (UAS) on July 1, 2025.
United States Transport

The U.S. Department of Commerce initiated new Section 232 investigations to assess the national security implications of imports of polysilicon and unmanned aircraft systems (UAS) on July 1, 2025.

Specifically, the Commerce Department is investigating polysilicon and its derivatives, and UAS and its parts and components. Polysilicon is a critical component in integrated circuits and solar panels. For polysilicon, the Commerce Department is seeking public comments on factors such as the:

  • Current and projected demand for polysilicon and its derivatives in the United States.
  • Extent to which domestic production of polysilicon and its derivatives can meet domestic demands.
  • Potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of polysilicon and its derivatives.

For UAS, the Commerce Department is seeking public comments on factors such as the:

  • Potential for foreign nations and companies to weaponize their control over supplies of UAS and their parts and components.
  • Potential for foreign nations and companies to weaponize the capabilities or attributes of foreign-built UAS systems and their parts or components.
  • Feasibility of increasing domestic capacity for UAS and their parts and components to reduce import reliance.

If the Section 232 investigations on autos and steel/aluminum are any indication, the Commerce Department's investigation may result in the imposition of tariffs on imported polysilicon and UAS.

Interested parties are invited to submit written comments, data, analyses, or other pertinent information on both topics by August 6, 2025.

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.

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