| THOMPSON COBURN TRADE ALERT – IMPORTS | |
| HEADLINE | Notice of Request for Public Comments on Section 232 Commerce Investigation of Imports of Robotics and Industrial Machinery |
| DATE | September 25, 2025 |
| AGENCY | Department of Commerce; Trump Administration |
| EFFECTIVE DATES | Deadline to Submit Comments in Docket No. 250924-0161 – October 17, 2025 (21 Days after Publication Date) |
| BACKGROUND | The Department of Commerce revealed that it initiated an investigation three weeks ago, on September 2, 2025, to determine the effects on national security of relevant machinery imports discussed further below. |
| DETAILS | The Department of Commerce's Bureau of Industry and
Security is seeking written comments, data, and information related
to the national security impacts of robotics and industrial
machinery imports. •Robotics and industrial machinery" includes robots, programmable computer-controlled mechanical systems, including CNC machine centers, turning & milling machines, grinding & deburring equipment, and industrial stamping and pressing machines. Other examples include tool changers and machine tools for cutting, welding, and handling work pieces, including application-specific specialty metalworking equipment. The Department is specifically interested in receiving comments and information regarding the following areas: • Current, projected, and optimal demand for robotics and industrial machinery and their parts and components in the U.S.; • Ability of domestic production to meet domestic demand; • Role of foreign supply chains, particularly from major exporters, in meeting U.S. demand; • Concentration of relevant imports from a small number of suppliers or foreign nations and the associated risks; • Impact of foreign government subsidies and predatory trade practices on domestic industry competitiveness; • Economic impact of artificially suppressed prices due to unfair trade practices and state-sponsored overproduction; • Risks from potential export restrictions by foreign nations; • Feasibility of increasing domestic production to reduce dependence on imports; • Impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security; • Potential for foreign control or exploitation of supply chains; • Ability of foreign persons to weaponize the capabilities or attributes of foreign-built robotic/machinery products. Notably specific to this investigation, Commerce also asked for comments on: • 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. Thompson Coburn is ready to provide assistance to anyone who may wish to submit comments. Please refer to the Notice linked below for filing instructions. Comments can be submitted electronically at www.regulations.gov, ID: BIS-2025-0257, and all comments should refer to XRIN 0694-XC138. |
| BASIS | Section 232 of the Trade Expansion Act of 1962; part 705 of the National Security Industrial Base Regulations (15 CFR parts 700 through 709) |
| CITE | Federal Register: Federal Register :: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Robotics and Industrial Machinery |
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