Section 232 Investigation Launched into Timber, Lumber, and Derivative Imports

This Saturday President Trump signed an Executive Order directing the U.S. Secretary of Commerce to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 (Section 232) on imports of timber, lumber, and their derivative products, citing the essential nature of this industry to United States national security. Paper products, furniture, and cabinetry are examples of derivative products specifically identified as being subject to the forthcoming investigation’s scope.

Pursuant to the President’s Executive Order, the results of this investigation will be released no later than 270 days after the date of the order, which is November 26, 2025. As required by law, the Secretary of Commerce will conduct the investigation in consultation with the Department of Defense. The investigation will assess the factors set forth in 19 U.S.C. 1862(d) and as follows:

1. the current and projected demand for timber and lumber in the United States;
2. the extent to which domestic production of timber and lumber can meet domestic demand;
3. the role of foreign supply chains, particularly of major exporters, in meeting United States timber and lumber demand;
4. the impact of foreign government subsidies and predatory trade practices on United States timber, lumber, and derivative product industry competitiveness;
5. the feasibility of increasing domestic timber and lumber capacity to reduce imports; and
6. the impact of current trade policies on domestic timber, lumber, and derivative product production, and whether additional measures, including tariffs or quotas, are necessary to protect national security.

If it is found that imports of timber, lumber, and their derivative products threaten national security, the Secretary of Commerce may recommend potential remedies to include tariffs, quotas on imports, export controls, incentives to increase domestic production, and policy recommendations to strengthen the U.S. timber and lumber industry through strategic investments and permitting reforms. The Order does not yet specify which Harmonized Tariff Schedule (HTS) classifications will be subject to these potential remedies, but there are already existing U.S. antidumping and countervailing duty orders covering certain lumber and wood-based products from various country sources.

Section 232 has been used in recent circumstances to examine, and in some cases impose a remedy concerning, imports of steel and aluminum articles, titanium sponge, NdFeB permanent magnets, vanadium, laminations for stacked cores, uranium, and automobiles.

In parallel Saturday, the Trump administration issued a separate Executive Order to immediately expand timber production in the United States. Citing concerns that reliance on imported lumber has hindered job growth, contributed to wildfires, degraded fish and wildlife habitats, increased construction and energy costs, and threatened economic security, the administration is calling for the reversal of “heavy-handed Federal policies” through the following actions, among others:

• The Secretary of the Interior and the Secretary of Agriculture will issue new or updated guidance to facilitate increased lumber production, reduce timber delivery times, and decrease supply uncertainty;
• The Secretary of the Interior and the Secretary of Commerce will develop a strategy to expedite Bureau of Land Management (BLM) and U.S. Forest Service (USFS) forestry projects, while also assessing whether existing authorities permit executive departments and agencies to delegate consultation requirements to other agencies;
• The Secretary of Agriculture and the Secretary of the Interior will submit to the President a plan outlining timber production targets for the next four years on federal lands managed by BLM and USFS;
• Relevant agencies will eliminate undue delays in permitting processes related to timber production while taking steps to suspend, revise, or rescind existing regulations, orders, guidance documents, policies, and other agency actions that impose burdens on industry production; and
• Federal members of the Endangered Species Committee, or their designees, will coordinate to submit a report to the President identifying obstacles to domestic timber production stemming from the implementation of the Endangered Species Act. The report will recommend procedural, regulatory, and interagency improvements to address these challenges.

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Cassidy Levy Kent’s attorneys, compliance professionals, economists, and licensed customs brokers have experience assisting clients navigating tariff changes, and participation in Section 232 investigations, including compliance with any Section 232 remedies. Our team is well-versed in the timber supply chain and downstream wood-based products, having secured favorable U.S. market access for such products in other trade remedy investigations. As this investigation takes shape, we expect further developments in this space and will continue to provide updates. Please contact us with any questions.