232 Investigation Updates on Critical Minerals, Semiconductors, Pharmaceuticals

  • ClientAdvisories.EffectiveDate: 4월 22, 2025
  • ClientAdvisories.AffectedRegions: 북미
  • ClientAdvisories.AdvisoryType: 관세

Critical Minerals

On April 15, 2025, the White House issued an Executive Order (EO) to begin an investigation on processed critical minerals and their derivatives as defined including rare earth elements.  The Commerce Department is required to issue a “draft interim report” within 90 days with their final recommendations due by October.  As a result of the investigation, the order confirmed there could be the “imposition of tariffs as well as other import restrictions”.  Critical minerals is defined in the notice by the “Critical Minerals List” published by the United States Geological Survey (USGS).

Comments Due on Semiconductors and Pharmaceutical products

On April 16, 2025, the Commerce Department, Bureau of Industry and Security, issued two notices for comment on the 232 Investigation on:

  • The imports of semiconductors and semiconductor manufacturing equipment (SME) and their derivative products. 
  • The imports of pharmaceuticals and pharmaceutical ingredients, including finished drug products, medical countermeasures, critical inputs, and derivative products of those items.

Interested parties are invited to submit written comments, data, analyses or other pertinent information to this investigation by May 7, 2025.  Resolutions on the investigations could be released as early as June.

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