Timber, Lumber, and Derivatives Get Their Own National Security Investigation

Mar. 3, 2025
By: David G. Forgue

Not content to let copper be the only commodity undergo a national security investigation under section 232, the White House has announced that imports of timber (unprocessed wood), lumber (wood processed into boards or planks), and their derivative products will also be investigated. Section 232 is the same provision that has been used to add duties to imports of steel, aluminum, and downstream products of each.

Interestingly, the Presidential Proclamation states that “[t]he United States faces significant vulnerabilities in the wood supply chain from imported timber, lumber, and their derivative products being dumped onto the United States market.” Regular readers will understand that “dumped” products are generally addressed using the antidumping laws. In fact, there are existing trade actions with respect to some wood products imported into the United States.

Nevertheless, the Proclamation also notes that the military spends roughly $10 billion on construction annually and invests in innovation to utilize wood products for construction. Cross-laminated wood products are specifically cited as an example of innovative construction material. Thus, the need for a strong domestic timber industry and manufacturing base to convert that domestic timber into construction materials has a national security aspect.

The focus of the investigation is both the ability of the U.S. industry to supply the U.S. market and the extent to which the U.S. market is impacted by foreign trade actions (including subsidies and predatory trade practices). A report from the Secretary of Commerce on this topic is due within 270 days of the proclamation, which is roughly November 26, 2025. Of course, Commerce could produce a report in less time as well.

Canada, China, Brazil, Chile, and Vietnam are top sources of imports of wood products. At this point the extent of “derivative products” has not been defined, so we do not know what articles made of wood might be included in the scope of the investigation.

If you have any questions about 232 investigations or the proper treatment of your wood articles upon important, do not hesitate to contact any attorney at Barnes, Richardson & Colburn, LLP.