Section 232 Investigation on Processed Critical Minerals & Derivative Products

In an Executive Order posted to www.whitehouse.gov late yesterday, President Trump has designated the Secretary of Commerce to initiate an investigation under Section 232 to determine what effects imports of processed critical minerals and their derivative products have on the US national security and economy.  The Secretary must provide a draft interim report for review within the next 90 days, and in turn, the President expects final recommendations on any potential tariff actions, policies to incentivize domestic production, processing and recycling and any other possible measures to ensure mitigation of national security risks by October 13, 2025.  There are no estimated rates mentioned in this publication.

Items in consideration are

  • Critical minerals as published by the US Geological Survey, including uranium

  • The 17 rare earth elements as established by the Department of Energy and any that are subsequently added to their list

  • Processed critical minerals which have undergone “the activities that occur after critical mineral ore is extracted from a mine up through its conversion into a metal, metal powder or a master alloy.  These activities specifically occur beginning from the point at which ores are converted into oxide concentrates; separated into oxides; and converted into metals, metal powders, and master alloys.”

  • Derivative products include “all goods that incorporate processed critical minerals as inputs.  These goods include semi-finished goods (such as semiconductor wafers, anodes, and cathodes) as well as final products (such as permanent magnets, motors, electric vehicles, batteries, smartphones, microprocessors, radar systems, wind turbines and their components,  and advanced optical devices).”

The full text of the order is found at Ensuring National Security and Economic Resilience Through Section 232 Actions on Processed Critical Minerals and Derivative Products – The White House.

In a separate fact sheet covering the same topic, it is noted that any tariff action that occurs as a result of these findings will replace the current IEEPA Reciprocal Tariff measures.  The final section of this document outlines all prior actions by this administration and is not representative of any actions that may be taken following this new S232 investigation. 

Fact Sheet: President Donald J. Trump Ensures National Security and Economic Resilience Through Section 232 Actions on Processed Critical Minerals and Derivative Products – The White House