On September 2, 2025, the U.S. Department of Commerce announced the initiation of a Section 232 investigation into imports of robotics and industrial machinery and related parts. The investigation, launched under the Trade Expansion Act of 1962, will assess whether these imports pose a threat to U.S. national security. The notice, set to be published in the Federal Register on September 26, 2025, officially begins the review process.
The scope of the investigation is broad, covering a wide range of equipment. This includes industrial robots, programmable and computer-controlled mechanical systems, CNC machining centers, milling and turning machines, grinding and deburring equipment, stamping and pressing machines, and automatic tool changers. It also encompasses specialized equipment such as autoclaves, industrial ovens, laser and water-jet cutting systems, and other metalworking and finishing machinery. The action does not cover unmanned aircraft systems, which are the subject of a separate Section 232 review.
As part of the investigation, the Department of Commerce is requesting public comments on issues identified under Section 705 of its regulations. These include current and projected U.S. demand for robotics and industrial machinery, the capacity of domestic producers to meet that demand, and the extent of reliance on imports. Other areas of focus are foreign government subsidies or trade practices, pricing and market effects of imports, and potential impacts on U.S. employment. The Department is also seeking input on whether foreign control or export restrictions could limit U.S. access to key machinery, and whether increased domestic production is feasible. Comments on the investigation are due to the Bureau of Industry and Security (BIS) by October 17, 2025. Following review of public input and internal analysis, the Department will prepare a report and recommendations for the President, who holds the final authority to determine whether imports of robotics and industrial machinery threaten national security and whether action, such as applying tariffs, is warranted.
Commerce Department Opens Section 232 Investigation into Medical Imports
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has also initiated a Section 232 investigation to determine whether imports of personal protective equipment (PPE), medical consumables, and medical equipment and devices threaten U.S. national security. The notice, set to be published September 26, 2025, launches a formal review of the nation’s dependence on foreign sources for essential medical goods.
Under the investigation, the scope of covered goods covers a broad set of categories. This includes diagnostic tools such as test kits, reagents, and laboratory instruments; therapeutic and life-support equipment such as ventilators, infusion pumps, and dialysis machines; and surgical and procedural instruments including scalpels, forceps, catheters, and implantable devices like stents and orthopedic hardware. The review also extends to medical consumables and delivery systems such as syringes, hypodermic needles, IV tubing, and related components that are indispensable to patient care.
Imaging and monitoring devices fall within the scope as well, including X-ray systems, MRI and CT scanners, ultrasound equipment, and patient monitoring technologies that are vital across hospitals and clinics. BIS also pointed to emergency and field medical equipment used in defense and disaster response settings, such as portable ventilators, trauma kits, and deployable diagnostic units.
BIS stated it is seeking detailed public input on issues such as the ability of U.S. manufacturers to meet domestic demand, the extent of U.S. reliance on foreign suppliers, potential vulnerabilities created by supply chain concentration, and the impact of foreign trade practices or government restrictions on exports. The agency emphasized that the inquiry will examine both short-term emergency preparedness and long-term national security risks tied to medical supply chains.
Stakeholders are invited to provide comments, data, and analysis through October 17, 2025.
Second Section 232 Steel/Aluminum Inclusion Window Now Open; Auto Parts Inclusion Window Coming Soon
The Bureau of Industry and Security (BIS) has launched the second opportunity this year for companies to seek inclusion of additional products under the Section 232 tariffs on steel and aluminum derivatives. The window, which opened September 15, will remain available through September 29, 2025, giving industry participants two weeks to file requests.
Applicants must provide detailed information for consideration. Each request must include contact details for the submitting party, the Harmonized Tariff Schedule (HTSUS) code for the item, a technical description, and an explanation of how the product qualifies as a derivative of steel or aluminum subject to the existing tariffs. Supporting data such as trade volumes, supply chain sourcing, and potential national security concerns tied to tariff coverage must also be submitted. BIS requires these elements to ensure a complete record for its review.
Completed submissions are to be sent via email to the Defense Industrial Base Programs office. Eligible requests will be posted on Regulations.gov for a 14-day public comment period before BIS makes a final determination. The agency has 60 days to issue decisions. This is the second derivatives inclusion round of 2025, following a May window that added hundreds of items to the tariff list. Tariffs on covered products can reach up to 50 percent, depending on steel or aluminum content. A third filing window is planned for January 2026.
Separately, the Department of Commerce has announced a new Section 232 tariff inclusion process specifically for automobile parts. Published September 17, the process establishes a formal channel for stakeholders to petition for certain auto parts to be included under the Section 232 automobile tariffs.
The requirements mirror those of the derivatives process—companies must submit technical specifications, HTSUS classifications, sourcing and volume data, and a rationale tied to national security concerns. Requests deemed complete will also be made available for public comment before Commerce issues determinations.
The auto parts process operates on quarterly two-week submission windows, beginning on the first business day of January, April, July, and October. The first submission window runs from October 1 to October 14, 2025.
DoD Issues Final Rule on Cybersecurity Certification Requirements
The Department of Defense (DoD) has finalized its Cybersecurity Maturity Model Certification (CMMC) rule, making certification a prerequisite for defense contract eligibility. Published September 10, 2025, the rule amends the Defense Federal Acquisition Regulation Supplement (DFARS) and takes effect November 10.
Contractors will be required to hold and maintain the CMMC level specified in their contract, register their CMMC Unique Identifier in the Supplier Performance Risk System (SPRS), and submit annual compliance affirmations. The rule applies throughout the supply chain, with subcontractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) also subject to the same provisions.
DoD plans to phase in the program over three years. To ease the transition, conditional certifications at Levels 2 and 3 will be permitted for up to 180 days if contractors are actively working through a Plan of Action & Milestones.
Officials caution, however, that full compliance will be mandatory across the defense industrial base. Misrepresenting certification status could lead to False Claims Act liability. Industry experts advise companies to begin aligning their systems with NIST SP 800-171 now to avoid delays or exclusion from contract opportunities.
European Parliament Adopts CBAM Simplification Package
On September 10, 2025, the European Parliament approved a simplification package for the Carbon Border Adjustment Mechanism (CBAM), introducing changes designed to reduce the compliance burden on small and occasional importers. The EU’s CBAM, first adopted in 2021 as part of the European Green Deal, aims to prevent “carbon leakage” by imposing a carbon cost on imports of energy-intensive goods. Following a transitional reporting phase launched in October 2023, the permanent regime will begin in 2026, when importers will need to purchase CBAM certificates tied to the carbon emissions embedded in their goods.
A central feature of the new package is the introduction of a mass-based exemption. Importers bringing in up to 50 tonnes per year of CBAM-covered goods — such as steel, aluminum, cement, and fertilizers — will now be exempt from reporting and certificate obligations. This replaces the previous value-based exemption of €150 per shipment and is expected to exempt about 90% of importers, primarily small and medium-sized enterprises (SMEs) and occasional traders, while still covering roughly 99% of the emissions associated with CBAM goods. Importers will be able to self-identify as “occasional CBAM importers” through customs filings, but must track their volumes carefully; if the threshold is exceeded, the CBAM rules apply to the entire year’s imports.
Other notable changes include narrowing the scope of emissions covered for certain steel and aluminum products, with only precursor emissions such as blast furnace and smelting now counted, while downstream processing steps are excluded. For importers above the 50-tonne threshold, reporting requirements will also be simplified, shifting from quarterly submissions under the transitional phase to a single annual declaration. Additionally, deadlines for purchasing and surrendering CBAM certificates have been extended, providing companies with more time to comply once the permanent regime takes effect.
The package still requires final approval by the Council of the European Union. If endorsed, the changes will be published in the EU’s Official Journal and take effect shortly thereafter, ahead of the permanent CBAM regime’s launch in 2026.
USTR Opens Input Process for 2026 USMCA Review
The U.S. Trade Representative (USTR) has kicked off preparations for the first review of the United States-Mexico-Canada Agreement (USMCA), set for July 1, 2026. The review comes six years after the trade deal officially took effect.
In a Federal Register notice released September 17, 2025, USTR called for public comments to help shape the upcoming discussions with Canada and Mexico. Businesses, labor groups, and other stakeholders are being asked to weigh in on how the agreement is performing, where it may need adjustments, and priorities for the joint review negotiations.
Feedback is sought on several fronts, including overall compliance and implementation, the role of the Competitiveness Committee, and the state of North America’s investment environment. USTR is also looking for views on strengthening U.S. competitiveness, advancing technological leadership, and safeguarding economic security, particularly in response to non-market trade practices.
Written comments and requests to testify must be submitted by November 3. A public hearing is scheduled for November 17 in Washington, D.C., followed by a brief rebuttal comment period.
Administration Publishes 2025 Spring Regulatory Agenda
The Administration released its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions on September 4, 2025, mapping out rulemaking priorities across the federal government. The agenda provides an overview of near-term actions expected within the coming year, as well as longer-range initiatives still in development, with many items directly affecting manufacturers.
Several significant rules are set for release in the months ahead. In September, the Environmental Protection Agency (EPA) plans to finalize its repeal of the 2009 Greenhouse Gas (GHG) endangerment finding, while the Department of Defense will issue an interim final rule updating procedures for implementing the National Environmental Policy Act (NEPA). That same month, a final rule adjusting acquisition-related thresholds for inflation is also expected. In October, the administration plans to release a proposal clarifying the definition of “waters of the United States” (WOTUS), along with two final actions: the Financial Crimes Enforcement Network’s rule on beneficial ownership reporting under the Corporate Transparency Act (CTA) and EPA’s review of the National Ambient Air Quality Standards (NAAQS) for ozone. November will bring a Department of Commerce rule terminating certain Section 232 investigations, while December is expected to include a proposed update to OSHA’s lock-out/tag-out (LOTO) standard and a proposed rule on joint employer liability under the Fair Labor Standards Act (FLSA). Looking ahead to 2026, EPA is preparing to finalize its particulate matter (PM2.5) standards in February, and OSHA plans to issue a notice of proposed rulemaking (NPRM) on mechanical power presses in April.
In addition to these scheduled actions, the Unified Agenda highlights longer-term priorities that are under consideration but not expected to advance within the next year. These include a possible advance notice of proposed rulemaking to revise the Hollings Manufacturing Extension Partnership program at the Department of Commerce, updates to OSHA’s occupational standards for crystalline silica exposure, revisions to the high-wage elements of the Labor Value Content rules under USMCA, and potential changes to the Fair Labor Standards Act exemptions for executive, administrative, and professional employees.