Executive Summary
On April 22, 2025, the Department of Commerce launched a Section 232 investigation (a power granted under the Trade Expansion Act of 1962) into processed critical minerals and their downstream products, specifically, to determine whether U.S. dependence on foreign supplies of these materials creates national security concerns. This was not limited to raw minerals but applied also to their derivatives, including batteries, motors and electronics. The DOC concluded that these imports, in current quantities and under current oversight, do threaten national security. On January 14, 2026, President Trump issued a proclamation in response. However, rather than impose tariffs or quotas, the proclamation directed the DOC and U.S. Trade Representative to pursue trade negotiations regarding U.S. dependence on these materials. More than seven months later, those negotiations remain ongoing. If the Administration finds the outcome to be inadequate, it retains the authority to impose new trade measures in the future.
What Happened
After the DOC’s 2025 Section 232 investigation and after public comments closed on May 16, 2025, the DOC concluded that imports of processed critical minerals and their derivatives did pose a risk to national security and transmitted those findings to the president. President Trump then issued Proclamation 11001, Adjusting Imports of Processed…