Reed Smith Client Alerts

On Monday, May 4, 2020, the U.S. Department of Commerce (Department) announced its decision to launch an investigation into whether laminations for stacked cores for incorporation into transformers, stacked and wound cores for incorporation into transformers, electrical transformers, and transformer regulators are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security.

The decision to launch an investigation under section 232 of the Trade Expansion Act of 1962, as amended (Section 232), was precipitated by inquiries and requests from multiple members of Congress as well as industry stakeholders.

The investigation will be conducted by the Department’s Bureau of Industry and Security (BIS). On May 19, 2020, BIS issued a Notice of Request for Public Comments regarding the Section 232 investigation.

This marks the sixth Section 232 investigation under the Trump administration.

Authors: Michael J. Lowell Yves Melin Manasi Venkatesh Sarah S. Wronsky Courtney Fisher

Current Section 232 investigation

On May 4, 2020, the Department announced its decision to launch a Section 232 investigation into laminations for stacked cores for incorporation into transformers, stacked and wound cores for incorporation into transformers, electrical transformers, and transformer regulators (hereinafter Products). The Department initiated the investigation on May 11, 2020, based on inquiries and requests from interested parties in the United States, including multiple Members of Congress, a grain-oriented electrical steel manufacturer, and producers of power and distribution transformers. Thereafter, on May 19, 2020, the Department issued a Notice of Request for Public Comments (Notice for Public Comments) regarding the Section 232 investigation.

Pursuant to the Notice for Public Comments, the Department has invited interested parties to submit written comments, data, analyses, or information pertinent to this investigation to the Office of Technology Evaluation within BIS. The Department is particularly interested in comments and information directed to the criteria listed in 15 CFR section 705.4 as they affect national security, including the following: