The U.S. Department of Commerce today issued notice that it initiated a new investigation covering robotics, industrial machinery, and their parts and components, pursuant to Section 232 of the Trade Expansion Act of 1962. The goods subject to this investigation form a critical part of the supply chain for a wide range of industrial products. Public comments concerning, e.g., U.S. demand, U.S. supply, and the broader role of these products in the American economy are due by October 17, 2025.
Many Industries Implicated
Commerce's notice indicates the investigation was launched September 2, 2025, although its existence was not previously made public. Compared to other recent Section 232 investigation notices, this provides more detail on the subject products. As Commerce explains, this investigation extends to:
robots and programmable, computer-controlled mechanical systems. This equipment spans 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. Application-specific specialty metalworking equipment used to treat, form, or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery is also included.
In short, although the goods themselves are relatively specialized, they are nonetheless used to manufacture a vast array of downstream industrial products. Thus, U.S. suppliers of the subject products, as well as downstream manufacturers that rely on them, may wish to submit information to Commerce regarding the role of subject products play in U.S. supply chains.
Moreover, the "parts" and "components" covered by this investigation could cover a broad swathe of products used for machinery, though much depend on how tariffs (if any) are ultimately formulated. For example, Section 232 tariffs on automobile parts cover certain HTSUS headings but also consider the imported article's status as an automobile part, as opposed to something else.
Broadening the Economic Focus
Commerce's notice requests that commenters address the following topics regarding U.S. demand, U.S. capacity, and import reliance that are common to nearly every Section 232 investigation:
- Current and projected U.S. demand;
- U.S. production capacity and the feasibility of increasing U.S. capacity;
- The role of foreign supply chains, particularly of major exporters, in meeting U.S. demand;
- The concentration of U.S. imports from a small number of suppliers and the associated risks;
- The impact of foreign government subsidies and predatory trade practices on U.S. robotics and industrial machinery industry competitiveness;
- The economic impact of suppressed prices due to unfair foreign trade practices and state-sponsored overproduction;
- The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of robotics and industrial machinery; and
- The impact of current trade policies on domestic production, and whether additional measures, including tariffs or quotas, are necessary to protect national security.
But Commerce goes further in today's notice, reintroducing questions about the potential for foreign supply chain control and weaponization that only recently arose in other investigations. The first concerns "the ability of foreign persons to weaponize the capabilities or attributes of foreign-built robotics and industrial machinery, and their parts or components," a type of question that debuted in the drones investigation announced in July. The second is a broad inquiry into the "potential for foreign control and exploitation of the robotics and industrial machinery supply chain." Such a question first appeared in the wind turbines investigation announced in August and appears to invite broader geopolitical discussion of the global market for subject products.
In addition, this notice introduces the following two new comment topics for the first time:
- The impact of the use or lack of use of robotics and industrial machinery on U.S. manufacturing employment; and
- The future role of robotics and industrial machinery in the production of items essential to national security or in activities related to national security.
The first of these underscores the breadth of industries that may have a stake in this investigation and suggests that Commerce's view of the relevant national security risks may extend to the overall health of the U.S. manufacturing base. The second is notable for its focus on future applications, indicating possible concerns with the trajectory of production automation in the United States. It also carries a potential geopolitical dimension tied to industrial competitiveness. For example, on the same day Commerce released this notice, The New York Times published a story that asserted "there are more robots working in China than the rest of the world combined."
Potential Timeline
Commerce's notice states that this investigation was initiated on September 2, 2025. The statute therefore provides Commerce until May 30, 2026, to conclude its investigation and transmit a report to the President. Commerce may, however, decide to move faster, and its relatively short public comment period suggests an intention to do so.
Once Commerce's report has been transmitted, the President has up to 90 days to determine whether imported products subject this investigation threaten to impair U.S. national security and determine a response, as well as a further 15 days to implement any such actions. Again, however, the President may determine to move more quickly. Indeed, the short timeline of the recently concluded Section 232 investigation of copper products suggests that both Commerce and the President acted significantly faster than the statute requires.
Section 232 actions under the second Trump Administration have thus far resulted in 50% tariffs on steel and steel derivative products, aluminum and aluminum derivative products, and copper derivative products, as well as 25% tariffs on automobiles and automobile parts. Certain exceptions to these tariff rates have been established in connection with trade "deals" involving trading partners such as the United Kingdom, European Union, and Japan. There is no guarantee that the new investigation will have a comparable outcome, but past actions may provide some indication of the level of tariff treatment that the President views as necessary to address imports in the Section 232 context. That said, there is no statutory requirement that the President impose any tariffs in response to a Section 232 report.
Preparing Supply Chains
Cassidy Levy Kent's attorneys, economists, compliance experts, and licensed customs brokers are ready to help companies develop strategic responses to the latest changes in U.S. tariff policy and plan for potential developments. Cassidy Levy Kent has extensive experience counseling clients in the manufacturing sector to plan compliant supply chains that manage tariff risks, and we routinely assist with preparing and filing comments for consideration in Section 232 investigations. Our team's deep familiarity with trade law and policy enables clients adapt and stay ahead of the curve.
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