What the US Administration's Section 232 investigation means for critical minerals

On 15 April 2025, US President Donald Trump signed an Executive Order directing the US Secretary of Commerce to initiate a Section 232 investigation, under the Trade Expansion Act of 1962, to evaluate the national security risks posed by US reliance on imported processed critical minerals and their derivative products.

The investigation assesses "vulnerabilities in supply chains, the economic impact of foreign market distortions, and potential trade remedies to ensure a secure and sustainable domestic supply of these essential materials".

This follows an earlier Executive Order, signed by President Trump in late February 2025, to launch a Section 232 investigation into how copper imports threaten America's national security and economic stability. The Commerce Department must deliver its findings from the copper tariff investigation within 270 days of initiation, with the report expected in November 2025.

Under the latest Executive Order, a comprehensive 180-day investigation will "culminate in a report detailing risks and providing recommendations to strengthen domestic production, reduce dependence on foreign suppliers, and enhance economic and national security".

These recommendations could include tariffs and other import restrictions; policies to incentivise domestic production, processing and recycling; and any other measures to mitigate national security risks. Should President Trump decide to impose tariffs, any resulting tariff rate imposed under Section 232 would take the place of the current reciprocal tariff rate, pursuant to Trump's 2 April 2025 Order. 

What minerals and products are covered by the Executive Order?

The Executive Order relates to imported processed critical minerals and their derivative products.

• "Processed critical minerals" refers to "critical minerals that 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" refers to "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)."
• "Critical minerals" encapsulates the 50 minerals on the Critical Minerals List published by the United States Geological Survey (USGS) (which includes the 17 rare earth elements), along with uranium.

Who could be affected?

As acknowledged in the Executive Order, the US is heavily reliant on importing its critical minerals and derivative products from a small number of foreign suppliers, particularly China (e.g. for rare earths, cobalt, graphite) and Latin America (for lithium). The investigation will zero in on all foreign sources of imports and the risks associated with each - particularly where they are deemed to employ "predatory economic, pricing, and market manipulation strategies and practices".

Industries challenged by any recommendations could therefore be wide-ranging, but would certainly include those industries with a particular reliance on imported processed critical minerals, including defence, manufacturing (especially electric vehicle manufacturers), and renewable energy developers.

On the other hand, allied nations together with domestic US mining and processing companies could stand to benefit from new investment opportunities and incentives.

Expected timeline

A draft interim report by the Secretary of Commerce is expected by 14 July 2025 (90 days after the date of the Executive Order) to the Secretary of the Treasury, the Secretary of Defense, the United States Trade Representative, the Assistant to the President for Economic Policy, and the Senior Counselor to the President for Trade and Manufacturing. Comments from these officials will then be provided within 15 days of the draft interim report.

The Secretary of Commerce will submit a final report and recommendations to the President within 180 days of the investigation's commencement, taking us to October 2025.

Presuming that the recommendation phase follows the same approach as previous Section 232 investigations, we might expect to see new measures implemented from January 2026 (90 days from anticipated final report and recommendations).

If you'd like to discuss how you might be affected by the above, please reach out to a member of our team.

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