On April 15, 2025, President Trump signed an Executive Order directing the U.S. Department of Commerce to initiate a Section 232 investigation into whether imports of processed critical minerals and their derivative products threaten to impair national security. The probe examines key supply chain vulnerabilities that could result in future trade actions, including targeted tariffs or other policy measures.
CRITICAL MINERALS: SECTION 232 INVESTIGATION SCOPE AND OBJECTIVES
The Commerce Department’s Bureau of Industry and Security (BIS) will evaluate imports of processed critical minerals and their derivative products in defense systems, energy infrastructure, and high-tech manufacturing. These include rare earth elements and refined materials essential to producing jet engines, missile systems, semiconductors, radar, communications, and advanced optical technologies.
BIS will analyze:
- The extent of U.S. reliance on foreign suppliers for critical mineral inputs
- Supply chain risks from geopolitical disruptions or export controls
- The economic impact of non-market practices such as price manipulation or production caps
- Gaps in domestic refining and processing capacity
- Trade tools available to reduce dependency and support U.S.-based production
The investigation will culminate in a formal report to the President. If imports are determined to impair national security, any resulting Section 232 tariffs will supersede reciprocal tariff rates previously announced under Executive Order 14257.
FOCUS ON STRATEGIC SUPPLY CHAINS: RARE EARTHS AND DEFENSE READINESS
Processed critical minerals are essential materials used to manufacture products that support U.S. national security and industrial resilience. Over the past year, foreign producers have introduced a series of export restrictions on minerals with military and high-tech applications.
Notably:
- China imposed licensing controls on gallium, germanium, antimony, and other high-purity materials.
- In April, China expanded its export ban to include six heavy rare earth metals and rare earth magnets used in aerospace, automotive, and semiconductor systems.
These actions elevated concerns about single-source dependencies and increased interest in domestic and allied production partnerships.
NEXT STEPS FOR U.S. IMPORTERS
U.S. importers of rare earth elements, derivatives, and associated downstream components are encouraged to:
- Review current sourcing strategies and assess exposure to covered materials
- Monitor Federal Register notices for public comment deadlines related to this investigation
- Evaluate eligibility for exemptions, especially for shipments in transit or entering bonded zones
Details on public comment requests and documentation requirements are expected from the Department of Commerce in the coming weeks.
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