President Trump Initiates Section 232 Investigations into Pharmaceuticals, Semiconductors, Critical Minerals and Trucks

Commerce’s slew of Section 232 investigations reflect a fundamental reevaluation of the U.S. supply chain for key inputs into critical industries and infrastructure. In its executive orders, the White House describes these actions as part of its strategic objective to boost domestic manufacturing capacity in certain advanced strategic sectors and reduce reliance on foreign imports, particularly those distorted by non-market policies and practices. These investigations differ from recent tariffs imposed under the International Economic Emergency Powers Act (IEEPA) in process and function. Commerce’s national security investigations offer stakeholders the opportunity for substantive participation, including through public comments. And while both the so-called “reciprocal” and fentanyl IEEPA tariffs focus on particular “emergencies,” Section 232 duties are intended to reorient supply chains.

The Trump administration signaled its intention to target pharmaceuticals, minerals and metals, and semiconductor products and derivatives by including them on a list of exemptions from the reciprocal tariffs announced on April 2, 2025. Practically speaking, many products subject to an exemption from the 10% global duty rate—and the escalatory 125% reciprocal tariffs on China—may soon be subject to additional duties under Section 232.

I. Investigation into Pharmaceuticals, Semiconductors, and Trucks
On April 1, 2025, Commerce initiated a Section 232 investigation to evaluate whether imports of pharmaceuticals, pharmaceutical ingredients and their derivative products threaten to impair the national security of the United States. On the same day, Commerce initiated an investigation into semiconductors, semiconductor manufacturing equipment (SME) and derivative products. The semiconductor investigation spotlights the Trump administration’s concerns over strategic dependencies, foreign state subsidies (especially regarding China), and possible vulnerabilities in the U.S. technology and defense sectors. In addition, on April 22, 2025, Commerce launched a Section 232 investigation to evaluate whether imports of trucks, truck parts and their derivatives threaten to impair U.S. national security.

Scope of Investigations

Pharmaceuticals. The Section 232 investigation into pharmaceuticals covers a wide range of products, including finished generic and non-generic drugs, active pharmaceutical ingredients (APIs), key starting materials, medical countermeasures and derivative products. Commerce explained that U.S. reliance on foreign sources for critical medical supplies raises the specter of sudden shortages, price hikes and the “weaponization” of supply chains by major exporting nations.

Semiconductors. The scope of the Section 232 investigation into semiconductors includes semiconductors, SME and derivative products, including foundational and leading-edge chips, microelectronics, substrates, bare wafers, SME components and products that contain semiconductors, such as in the electronics supply chain.

The semiconductor sector is concurrently under scrutiny by the Office of the U.S. Trade Representative (USTR) in an investigation under Section 301 of the Trade Act of 1974. The Section 301 action specifically targets China’s trade practices, including alleged state-sponsored subsidies, forced technology transfers and overcapacity in foundational semiconductors, including to the extent they are incorporated as components into downstream products and inputs into semiconductor fabrication. The Section 301 investigation will assess dependences and vulnerabilities that “create risks for certain critical downstream industries, as well as harm to U.S. semiconductor producers and foundries.” Consequently, semiconductor producers and downstream industries with a China nexus could be caught in overlapping protective measures under both Section 232 and Section 301 if both investigations culminate in new import restrictions. One through-line of these investigations remains the administration’s commitment to reshoring semiconductor fabrication in the U.S. to combat the strategic dominance of China in these sectors.

Trucks. As noted above, the Section 232 investigation into trucks and truck parts includes medium heavy-duty trucks, heavy-duty trucks, medium- and heavy-duty truck parts, and their derivatives. (The Section 232 duties on automobiles already in place are limited to light passenger vehicles and parts, and excluded trucks, which already have a higher MFN duty rate.) The term “trucks” refers to motor vehicles used for the transport of goods. “Medium heavy-duty trucks” are defined as trucks with a gross vehicle weight of more than 10,000 pounds and under 26,001 pounds. “Heavy-duty trucks” have a gross vehicle weight rating of 26,001 pounds or more. “Medium- and heavy-duty truck parts” refer to individual components and systems of medium- and heavy-duty trucks, including engines and engine parts, transmissions and powertrain parts, and electrical components.

Next Steps
Commerce has invited public comments in the three investigations. The deadlines are as follows:

• The current deadline to provide comments for the pharmaceutical and semiconductor investigations is May 7, 2025.
• The current deadline to provide comments for the truck investigations is May 16, 2025.

Commerce must complete its review and report findings to the President in each investigation within 270 days (although the investigation can be completed prior to 270 days). If Commerce concludes that covered pharmaceutical, semiconductor or vehicle imports threaten to impair national security, the President must decide within 90 days whether to impose remedial measures.

III. Section 232 Investigation into Critical Minerals
On April 22, 2025, Commerce formally launched a Section 232 investigation to evaluate whether imports of processed critical minerals and their derivative products threaten to impair national security. The associated Executive Order (the critical minerals Section 232 EO) provides that critical minerals are the “building blocks” of a modern economy and cites concerns regarding the handful of countries—namely China—that dominate both the global mining and processing of critical minerals.

Scope of Critical Minerals Investigation
As noted above, the scope of the Section 232 investigation includes processed critical minerals and derivative products. These terms are defined as follows.

• “Critical minerals” includes minerals included in U.S. Geological Survey’s “Critical Minerals List” and any subsequent list and uranium. (The current list from 2022 is available here. These lists are typically updated every three years.)
• “Processed critical minerals” means “critical minerals that have undergone the activities that occur after critical mineral ore is extracted from a mine through its conversion into a metal, metal powder, or a master alloy.” This includes conversion of ore into oxide concentrates, separation into oxides, and conversion into metals, metal powders and master alloys.
• “Derivative products” means “all goods that incorporate processed critical minerals as inputs” including semi-finished goods (such as anodes and cathodes) and final products (such as motors, batteries, radar systems, wind turbines and their components, and advanced optical devices, among other things). Note that these products also contain semiconductors.

Timeline and Next Steps
Commerce has invited comments in connection with the investigation, which are due on May 16, 2025. The critical minerals Section 232 EO directs the Secretary of Commerce to conduct an expedited investigation. Within 90 days, or by July 14, 2025, the Secretary must submit a draft interim report for internal review to the Secretary of the Treasury, the Secretary of Defense, the USTR, and senior White House economic and trade advisors. These officials have 15 days to provide comments. A final report and recommendations must then be submitted to the President within 180 days of the investigation’s commencement, or by no later than October 12, 2025. This is a notably faster and more specific timetable than semiconductors or pharmaceuticals investigations.

Common Themes
In a Section 232 investigation, Commerce is required to assess a number of factors enumerated in 19 U.S.C. 1862(d). In addition, in the case of the investigations initiated under the second Trump administration, Commerce has been directed to consider various additional factors including, among other things, the impact of foreign government subsidies, overcapacity, and non-market policies and practices, and the potential for export restrictions by foreign nations. This may be in response to Chinese export restrictions or bans targeting various minerals including gallium, germanium, tungsten, antimony and rare earths (where China has obtained a dominant market position), and the significant U.S. government reporting regarding the impact of non-market policies and practices on supply chains.

Interplay with the Reciprocal Tariffs and Potential Outcomes
On April 2, 2025, the Trump administration’s EO on reciprocal tariffs introduced a 10% universal tariff on most imports, going into effect on April 5, with much higher country-specific tariffs slated for April 9, 2025. However, on April 8, 2025, the Trump administration paused implementation of the country-specific tariffs for 90 days while trade talks and domestic consultations continue. During this pause, the baseline 10% universal tariff remains in effect and applies to all countries subject to the paused country-specific tariffs. (An exception is China, which currently has a reciprocal tariff of 125%.)

President Trump has previously stated that he plans to impose tariffs on pharmaceuticals and semiconductors. Given the broad scope of these investigations and the complexity of the supply chains, the Trump administration may consider imposing tariff-rate quotas in lieu of tariffs for certain products, duty mitigations for U.S. content, or exclusions of certain products where particular requirements are met (such as compliance with U.S.-Mexico Canada rules of origin or certain U.S. manufacturing requirements). Also, the Trump administration may consider components of the supply chain to be part of sectoral arrangements the USTR is attempting to negotiate with certain countries and sectors, as noted in the Executive Summary to the Report to the President on the America First Trade Policy.

With respect to minerals, the critical minerals Section 232 EO directs Commerce to consider a range of remedies and responses when making recommendations under Section 232. These include both traditional import duties and restrictions and other security and industrial policy measures, such as safeguards to prevent circumvention or weakening of any Section 232 measures; policies to encourage domestic production, processing and recycling; and any additional actions deemed necessary to address national security risks, including measures authorized under the IEEPA. As we discuss here, on March 20, 2025, the Trump administration issued an Executive Order invoking emergency powers to boost U.S. critical mineral development (including for processing), signaling to producers, buyers and investors that domestic production is an important component of broader efforts to secure mineral supply chains. This includes working with allies and partners, particularly in resource-rich countries to advance access to feedstock for domestic processing.

These wide-ranging options (in addition to import adjustments) signal that the Trump administration may, at least in the case of certain minerals, consider broader actions to support mineral supply chain security. Notably, in the first Trump administration, following prior Section 232 investigations into minerals and materials, the Administration recommended measures to support further analysis through working groups, which recommended policies to support domestic production and work with allies and partners to advance supply chain resiliency.

IV. The Next Chapter of the America First Trade Policy
Foreign exporters and domestic companies relying on imports of pharmaceuticals, semiconductors, critical minerals, trucks and the wide range of affected downstream products now face a new chapter of volatility in trade costs and compliance obligations. The new Section 232 investigations signal the Trump administration’s continued resolve in considering restrictions on imports viewed as critical for defense, innovation and economic stability. The ongoing engagement with and responses of U.S. trading partners, either through deal-making or the imposition of retaliatory tariffs and other countermeasures, will continue to shape market forces and global trade.