The Trump Administration announced a Section 232 investigation into imports of industrial machinery and robotics, and offers businesses the chance to provide their perspective on how tariffs would affect them. The announcement kicks off the process, which could lead to tariffs on a range of imports that manufacturers and businesses use to make products. However, companies have the chance to offer their views and shape the outcome. McCarthy Consulting LLC works with businesses to devise a plan to craft not only the winning message, but also the effective strategy to engage the Administration to ensure it listens. This includes submitting written views during the comment period, meetings with Administration officials, engaging your elected representatives in Congress to lobby the Administration, and public relations campaigns.
Companies can tailor their strategies to their specific situations, including advocating for:
- Adding products that could be subject to tariffs to support the domestic production of a certain product,
- Removing products from the proposed list to prevent tariffs on goods that a business imports
- Targeting tariffs on imports from specific countries. For example, if a business imports machine tools for cutting from Germany, it could suggest that tariffs not be applied to imports from countries that don't unfairly subsidize production (e.g., Germany) and only apply to countries that unfairly boost their companies through government subsidies (e.g., China).
- Supporting tariffs on the proposed list,
- Highlighting the lack of domestic supply of a particular piece of industrial machinery/robotics/equipment and therefore the need to import,
- Sharing how the various tariffs are affecting profits and demonstrating that additional tariffs on industrial machinery and robotics would cause harm to the business.
Here is the key information on the public comment period process:
Due Date: Comments must be submitted by October 17th
Scope: The proposed list of imports included in the investigation is below. Commenters can request changes to this list, including adding products not on this list or removing products from it.
Robots and programmable, computer-controlled mechanical systems, including CNC machining centers; turning and milling machines; grinding and deburring equipment; industrial stamping and pressing machines; automatic tool changers; jigs and fixtures; machine tools for cutting, welding, and handling work pieces; and application-specific specialty metalworking equipment used to treat, form, or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery.
What can be included in a comment? Commenters have the flexibility to include any perspective and information that is important to them. But the Administration listed certain topics it is most interested in hearing about:
- current and projected demand for covered goods in the U.S.
- the extent to which domestic production can meet that demand
- the role of foreign supply chains, particularly major exporters, in meeting that demand
- the concentration of U.S. imports from a small number of suppliers or foreign nations and the associated risks
- the impact of foreign government subsidies and predatory trade practices on U.S. industry competitiveness
- the economic impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overproduction
- the potential for export restrictions by foreign nations or for foreign control or exploitation of the supply chain
- the ability of foreign nations to weaponize their control over supplies of covered products or of foreign persons to weaponize the capabilities or attributes of foreign-built products
- the feasibility of increasing domestic capacity to reduce import reliance
- the impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security
Official Notice:
https://public-inspection.federalregister.gov/2025-18749.pdf
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