On March 1, 2025, President Trump issued an Executive Order directing the U.S. Department of Commerce (“Commerce”) to initiate a Section 232 investigation into imports of timber, lumber, and their derivative products. This is the same law that was used to impose additional tariffs on imports of steel, aluminum, and their derivative products.
The full scope of the new investigation is not yet certain. The Executive Order defines the term “timber” to refer to wood that has not been processed and defines the term “lumber” as wood that has been processed, including wood that has been milled and cut into boards or planks. The Executive Order provides three examples of derivative products (paper products, furniture, and cabinetry), but does not provide a complete list and additional derivative products are likely to covered by the investigation.
In addition to the factors required by the Section 232 statute (19 U.S.C. 1862(d)), the Executive Order directs Commerce to consider other factors, including 1) the current and projected demand for timber and lumber in the United States; 2) the extent to which domestic production of timber and lumber can meet domestic demand; 3) the role of foreign supply chains, particularly of major exporters, in meeting United States timber and lumber demand; 4) the impact of foreign government subsidies and predatory trade practices on United States timber, lumber, and derivative product industry competitiveness; 5) the feasibility of increasing domestic timber and lumber capacity to reduce imports; and 6) the impact of current trade policies on domestic timber, lumber, and derivative product production, and whether additional measures, including tariffs or quotas, are necessary to protect national security.
The Order requires Commerce to submit a report within 270 days, by June 30, 2025, outlining the following: (1) its findings as to whether imports of timber, lumber, and their derivative products threaten national security; (2) recommendations on actions to mitigate such threats, including potential tariffs, export controls, or incentives to increase domestic production; and (3) policy recommendations for strengthening the United States timber and lumber supply chain through strategic investments and permitting reforms. The Section 232 investigative process allows for public comment and a Federal Register notice should be published in the near future announcing a schedule for public comments and public hearing.
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