Trucks and Minerals Trade Investigations

The U.S. Department of Commerce announced the initiation of two separate national security investigations under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862).

The investigations will evaluate the impact of (1) processed critical minerals and their derivative products, and (2) imports of medium- and heavy-duty trucks and related parts, on the national security of the United States.

Reorienting Supply Chains

"Commerce’s slew of Section 232 investigations reflect a fundamental reevaluation of the U.S. supply chain for key inputs into critical industries and infrastructure,"  asserts Pillsbury's International Trade Team in an April 25th note.  

"In its executive orders, the White House describes these actions as part of its strategic objective to boost domestic manufacturing capacity in certain advanced strategic sectors and reduce reliance on foreign imports, particularly those distorted by non-market policies and practices.

"These investigations differ from recent tariffs imposed under the International Economic Emergency Powers Act (IEEPA) in process and function. Commerce’s national security investigations offer stakeholders the opportunity for substantive participation, including through public comments. And while both the so-called “reciprocal” and fentanyl IEEPA tariffs focus on particular “emergencies,” Section 232 duties are intended to reorient supply chains'" the note concludes.

Processed Critical Minerals Investigation

The Bureau of Industry and Security (BIS) will assess whether U.S. reliance on foreign-sourced processed critical minerals—including rare earth elements—poses a risk to national security. The Commerce Department noted that these materials are essential to civilian infrastructure and defense applications, and emphasized that China currently dominates global processing capacity for 30 of 44 recognized critical minerals.

“The United States should not allow foreign adversaries to have a chokehold on critical inputs for our economy and defense industrial base,” said Under Secretary of Commerce for Industry and Security Jeffrey Kessler. “Under President Trump’s leadership, the Commerce Department will carefully assess the risks posed by external threats and supply chain vulnerabilities.”

Medium- and Heavy-Duty Truck Imports Investigation

In a separate announcement, BIS initiated a Section 232 investigation into the effects of imports of medium-duty trucks, heavy-duty trucks, and associated parts. The probe will determine whether current import levels impair U.S. national security by undermining domestic production capacity vital to defense and infrastructure sectors.

“A strong and resilient automotive and truck industry is vital to our national security,” said Kessler. “This investigation will ensure American truck manufacturing remains protected.”

Public Comment Period Open Through May 16

The Department has opened public comment periods for both investigations. Interested stakeholders are invited to submit data, analysis, and comments by May 16, 2025, via the Federal eRulemaking Portal at www.regulations.gov.

• Critical Minerals Docket Number: BIS-2025-0025

• Truck Imports Docket Number: BIS-2025-0024

Trade Implications

The mineral investigation is expected to focus heavily on U.S. vulnerabilities in refining and processing operations dominated by Chinese firms, particularly amid rising geopolitical tensions. The outcome could lead to recommendations for investment incentives, import restrictions, or new tariffs on foreign-processed minerals.

The truck import investigation could significantly impact Mexico, the largest exporter of medium- and heavy-duty trucks to the United States. A January 2025 trade study found that U.S. imports of these vehicles from Mexico have tripled since 2019.

Mexico also leads globally in exports of tractor trucks, 95% of which are sold to the U.S. market. Potential trade actions may include new tariffs that could disrupt cross-border supply chains and affect bilateral trade flows.

Truck makers and parts manufacturers with assembly plants and factories in Mexico include Freightliner, Kenworth, Navistar, Hino, International, DINA, MAN SE, Mercedes-Benz, Isuzu, Scania, Cummins and Detroit Diesel, according to ANPACT.

National Security Investigation of Imports of Processed Critical Minerals and Derivative Products

National Security Investigation of Imports of Trucks