Manufacturers tariffs update: What’s ahead for U.S. manufacturing
Tariff policy continues to evolve rapidly, and manufacturers are feeling the impact.
Section 232 investigations are targeting imports tied to national security, with a growing list of goods under review — from semiconductors to industrial machinery. These investigations often lead to swift tariff actions, especially on raw materials like steel, aluminum, copper and timber, as well as their derivatives.
Here’s an overview of recent tariff updates and their potential impacts:
An overview of tariffs and U.S. manufacturing
The Trump administration continues to use different avenues to impose tariffs. Tariffs and trade dynamics are changing weekly and sometimes daily.
President Trump is predominantly using three different avenues to impose tariffs:
- Section 301 through the Department of Commerce: This tariff focuses on specific countries and HTS codes. A portion of the tariffs on Chinese goods is imposed under Section 301. The Court of International Trade has upheld the legality of using this section to impose tariffs on U.S. imports.
- Section 232 through the U.S. Trade Representative: These tariffs focus on specific HTS codes and investigations into national security risks the U.S. may have due to reliance on certain imports. The process of imposing tariffs under section 232 requires an investigation period by the Department of Commerce and a time for industry to provide comments on the potential tariffs. Each time an investigation into a new product occurs, the Department of Defense has up to 270 days to investigate before issuing a Federal Register notice. After that initial investigation, additional HTS codes can be added to “derivative lists” as part of the inclusion process. The time frame to add to the derivative list is far shorter, and tariffs are typically imposed quickly. The Supreme Court has upheld the legality of using this section to impose tariffs on U.S. imports.
- International Emergency Economic Powers Act (IEEPA):In President Trump’s second term, he has also started using IEEPA to impose tariffs. There is debate about if President Trump can legally use IEEPA to impose tariffs. The Supreme Court will be hearing the case on November 5, 2025.
Section 232 investigations
If the Supreme Court rules that President Trump cannot use IEEPA to impose tariffs, that does not mean tariffs will “go away.” President Trump will continue using Section 232 as the primary vehicle to impose tariffs.
There are currently 10 pending investigations under Section 232 on the following goods and other investigations have already been completed with tariffs in place:
- Semiconductors
- Robots and industrial machinery
- Pharmaceuticals
- Critical minerals
- Medium- and heavy-duty trucks and parts
- Commercial aircraft
- Polysilicon
- Unmanned aircraft systems
- Wind turbines
- Personal protective equipment
It is unclear what the investigations will show or what the tariff outcome for each of these goods will be. However, based on historical evidence, it is likely that President Trump will put tariffs on these goods after the investigations are completed.
The Section 232 investigation and inclusion process is, and will likely continue to be, a primary avenue to impose tariffs. In addition to the goods listed above, numerous goods have already undergone the investigation process and have already or expect to have tariffs imposed.
Primary Section 232 tariffs that are currently impacting manufacturers are raw material tariffs on steel, aluminum, copper, timber and lumber. In addition to the materials, derivatives of these goods are also being tariffed, such as a steel part that goes into a machine or an upholstered piece of furniture built using timber.
Upcoming tariffs to watch
Manufacturers should stay prepared for tariffs that could significantly impact supply chains and production costs.
Sources in Washington suggest that the Department of Commerce may release the list of additional products subject to the tariffs by the end of November. With investigations underway and new inclusion processes being announced, staying informed is essential to mitigate risk and plan ahead.
Steel and aluminum tariffs
September 29, 2025, marked the end of the second round of the 232 steel and aluminum tariff inclusion process, following an announcement in August where the Commerce Department added more than 400 imports to the tariff list.
On September 29, 2025, the U.S. Department of Commerce completed accepting applications to expand the Section 232 steel and aluminum tariffs to cover products made from those metals, known as derivatives. Three times annually, the department will accept requests from U.S. companies and trade associations to expand the 50% tariffs to cover the entire value of the product comprised of steel or aluminum.
For imports added to the tariff inclusion list with materials in addition to steel and aluminum, the value of the non-steel or aluminum is subject to the country-specific reciprocal tariff rate, which ranges from 10% to 41%.
Copper tariffs
At the end of October, the Trump administration is scheduled to announce the process for adding products made of copper to that separate Section 232 tariff action to expand the list of goods to which the 50% tariff is applied.
Lumber tariffs
On October 10, 2025, U.S. Customs and Border Protection formally published guidance on the implementation of Proclamation 10976, “Adjusting Imports of Timber, Lumber, and Their Derivative Products into the United States.” The Section 232 tariff rates range from 10% to 25% on imports of softwood lumber, upholstered wooden furniture products and completed kitchen cabinets/vanities and parts.
President Trump indicated that tariffs on some imports may increase to 30% and up to 50% on January 1, 2026.
Robotics and industrial machinery
There is also currently an investigation underway into imports of “robotics and industrial machinery,” including their components and parts. The public comment period ended in mid-October.
Depending on the outcome of the investigation, this could result in a tariff, quota or other import restriction on all machines, such as CNC machines, robots, grinding equipment, stamping equipment, welding, etc.
Why Wipfli
Stay ahead of tariff changes impacting your supply chain. Wipfli’s industry-experienced team can help you navigate evolving trade policies, mitigate risks and build resilience. Visit our tax updates page for strategic insights to protect your operations today.
Get the latest tax updates
