U.S. Initiates Section 232 Probes into Imported Robots, Industrial Machinery and Medical Equipment

On September 24 local time, the U.S. Department of Commerce’s Bureau of Industry and Security published Federal Register notices confirming that Section 232 investigations were opened on September 2 into imports of robots and industrial machinery, and into imports of medical equipment. These inquiries are being conducted under Section 232 of the Trade Expansion Act, which empowers the President to impose tariffs on goods determined to threaten national security; the Department is required to submit policy recommendations within 270 days.

The newly announced reviews broaden the range of sectors potentially subject to tariff action as part of an administration effort to strengthen domestic manufacturing by raising import costs. For the robots and industrial machinery probe, respondents are asked to quantify expected domestic demand for robots and industrial machinery and to assess whether U.S. production capacity for such equipment and components can satisfy that demand, while explaining the role of foreign supply chains in meeting U.S. requirements. The scope explicitly covers robots and programmable computer‑controlled mechanical systems and extends to numerical‑control machining centers, lathes, milling machines, grinding and deburring equipment, industrial stamping and press machinery, automatic tool changers, jigs and fixtures, and machine tools used for cutting, welding and workpiece processing. Also included are application‑specific metalworking systems such as autoclaves and industrial ovens, metal finishing and processing equipment, electrical discharge machines, and laser and waterjet cutting tools. Unmanned aerial systems are excluded from this particular probe and are subject to a separate Section 232 review.

The medical equipment investigation requests detailed projections of demand for personal protective equipment and medical devices, an evaluation of the extent to which domestic production satisfies U.S. needs, an assessment of the role of foreign supply chains, and an appraisal of the effects of foreign government subsidies and predatory trade practices. The investigation targets imports of PPE, medical consumables and medical equipment. PPE is defined to include items used in healthcare settings such as surgical masks, N95 respirators, gloves, gowns and related components. Medical consumables cover disposable or short‑term items used in diagnosis, treatment and prevention—examples provided include syringes, needles, infusion pumps, forceps, scalpels, IV bags, catheters, tracheostomy tubes, anesthesia devices, gauze, sutures and diagnostic reagents. Medical equipment encompasses durable care devices such as wheelchairs, walkers and hospital beds, while medical devices encompass instruments and machines used for diagnosis, monitoring or treatment, including pacemakers, insulin pumps, coronary stents, heart valves, hearing aids, prosthetics, glucose monitors, orthopedic devices, CT and MRI scanners, electrosurgical units, X‑ray and other radiology equipment, ventilators and related imaging systems.

Pharmaceuticals—prescription and over‑the‑counter drugs, biologics and specialty medicines—are not covered in this probe because they are under review in a separate Section 232 proceeding.
Analysts observe that these investigations widen the universe of industries that could face tariffs as the administration seeks to incentivize domestic production of strategically important goods.

Prior Section 232 inquiries and measures have targeted automobiles, copper, steel and aluminum, and the administration has previously launched probes into pharmaceuticals, semiconductors, aircraft, critical minerals and medium‑ and heavy‑duty trucks. Should the U.S. Supreme Court ultimately invalidate tariffs imposed under the International Emergency Economic Powers Act, Section 232 investigations could provide an alternative legal pathway for protective measures. Section 232 processes are procedurally lengthier, however, typically requiring extended study before any tariff recommendations are enacted, and thus yield a slower operational cadence than emergency‑based tariffs.

Earlier this month, National Economic Council Director Kevin Hassett noted publicly that, if the Supreme Court does not sustain prior emergency‑powers tariffs, other statutory mechanisms such as Section 232 remain available as options for imposing trade remedies