Commerce Initiates Section 232 Investigations into Drones and Polysilicon Imports

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Jul. 15, 2025
By: Austin J. Eighan

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) initiated two new investigations under Section 232 of the Trade Expansion Act of 1962, as amended, to determine whether drone and polysilicon imports pose a risk to national security.

The first investigation covers unmanned aircraft systems (i.e., drones), including their associated parts and components. The second focuses on polysilicon and its derivatives, which serve as key solar energy component inputs. The Secretary of Commerce tasked BIS with examining the extent to which national security requires these items to face additional tariffs, quotas, or other “additional measures” upon import.

Once BIS finalizes its investigation, the Secretary will recommend to the President whether drones and polysilicon articles should join the growing list of goods subject to Section 232 measures. Since taking office in January, the Trump Administration has opened seven Section 232 investigations:

1.     Copper – Initiated March 10, 2025, with 50% duties expected August 1

2.     Timber and Lumber – Initiated March 10, 2025

3.     Semiconductors and Semiconductor Manufacturing Equipment – Initiated April 1, 2025

4.     Pharmaceuticals and Pharmaceutical Ingredients – Initiated April 1, 2025

5.     Trucks – Initiated April 22, 2025

6.     Processed Critical Minerals and Derivative Products – Initiated April 22, 2025

7.     Commercial Aircraft and Jet Engines – Initiated May 1, 2025

BIS encourages interested parties to submit written comments by August 6 via the Federal rulemaking portal under docket number BIS-2025-0059 for drones and BIS-2025-0028 for polysilicon and its derivatives, referencing XRIN 0694-XC130 and XRIN 0694-XC128 respectively.

If your company has concerns about the scope of the investigations or would like to file a comment, please reach out to one of our attorneys at Barnes, Richardson & Colburn.