Upcoming Section 232 Trade Actions: What Importers Need to Know on January 20, 2026

Presidential Proclamations on Critical Minerals and Semiconductors Set to Reshape Key Supply Chains.

On January 20, 2026, two new Presidential Proclamations will be published in the Federal Register, each carrying significant implications for U.S. importers across manufacturing, electronics, automotive, aerospace, energy, and advanced technology industries. These actions follow extensive national security investigations under Section 232 of the Trade Expansion Act of 1962 and target two categories central to U.S. economic and defense capabilities:

• Proclamation 11001 – Processed Critical Minerals and Derivative Products; Adjustment
• Proclamation 11002 – Semiconductors, Semiconductor Manufacturing Equipment, and Derivative Products; Adjustment

Below is a clear breakdown of what’s coming and how your business can prepare.

Proclamation 11001: Processed Critical Minerals & Derivatives

Why It Matters

Critical minerals such as cobalt, nickel, rare earth elements, gallium, germanium, lithium, uranium, indium, yttrium, and others power nearly every modern industry — from defense systems and energy storage to electronics, fiber optic networks, medical technology, and vehicles.

Commerce’s Section 232 investigation found that:

• The U.S. is fully import dependent for 12 critical minerals and 50%+ reliant on 29 others.
• Even where the U.S. mines minerals domestically, it lacks sufficient processing capacity, creating a strategic vulnerability.
• These minerals and their derivative products are embedded throughout the 16 critical infrastructure sectors, including energy, communications, transportation, defense, chemicals, and manufacturing.

What the Proclamation Does

The January 20th publication will:

• Direct the U.S. Trade Representative and Department of Commerce to negotiate new or expanded agreements with partner countries to secure stable, diversified mineral supply chains.
• Establish a 180-day negotiation window.
• Enable the President to impose minimum import prices, tariffs, quotas, or other remedial actions if effective agreements are not reached.

What Importers Should Expect

• Potential new tariff lines or price floor mechanisms. • Increased scrutiny on origin, processing location, and supply chain mapping.
• Volatility in procurement costs for industries dependent on magnets, batteries, catalysts, alloys, and electronic components.

Proclamation 11002: Semiconductors & Semiconductor Manufacturing Equipment

Why It Matters

Semiconductors are foundational to national defense, critical infrastructure, artificial intelligence, communications, medical devices, and advanced manufacturing. The investigation determined that:

• The U.S. manufactures only ~10% of the chips it consumes.
• The country remains heavily reliant on foreign semiconductor fabrication, lithography equipment, and other SME tools.
• Strategic chips — including those supporting AI and secure communications — require stable and trustworthy supply chains.

Immediate Trade Impact: 25%

Tariff Proclamation 11002 triggers:

• A 25% ad valorem tariff, already effective as of January 15, 2026, on specific advanced computing chips and derivative products if they do not contribute to building out the U.S. semiconductor supply chain.

Key provisions:

• No drawback allowed.
• Foreign Trade Zone (FTZ) entries for covered chips must use privileged foreign status.
• Certain end-use exceptions exist for imports that directly support U.S. production capacity.

What Comes Next

Commerce outlined a two-phase approach:

Phase 1 (Immediate):

Narrow, high-priority tariffs on sensitive AI-related or advanced semiconductor inputs.

Phase 2 (Future):

Broader tariffs or negotiated solutions, depending on international cooperation, paired with programs to encourage U.S. domestic semiconductor investment.

What This Means for Your Business

1. Review Your HTS Classifications Immediately - Determine whether any imported materials, chips, wafers, substrates, or SME tooling appear in the forthcoming proclamation annexes.
2. Prepare for New Tariff Scenarios -  Both proclamations open the door to future tariff expansions — not just on raw materials, but on subcomponents, derivative products, and downstream assemblies.
3. Strengthen Supplier Documentation & Origin Controls - Expect heightened compliance expectations from Customs and potential requests for detailed processing stage evidence.
4. Watch for Additional Guidance After January 20 - CBP is expected to issue CSMS notices, and Commerce/USTR may release FAQs, annex clarifications, and implementation instructions shortly after publication.

How We Can Help

Our Trade Consulting team supports importers across various industries in navigating emerging Section 232 adjustments, including classification reviews, impact modeling, tariff mitigation strategies, and compliance planning. Our Customs Brokerage team supports accurate tariff application and entry filing, HTS and entry review at time of entry, post-entry & corrective actions, as well as ongoing monitoring of CBP CSMS messages and Federal Register notices. Reach out today to protect your supply chain operations. Tariff Response Unit.