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Last week, the U.S. Department of Commerce has initiated new Section 232 investigations on semiconductors, while President signed an Executive Order directing the initiation of a Section 232 investigation on critical minerals. Like previous Section 232 investigations (e.g., steel, aluminum), these probes can lead to additional tariffs.

Are derivative products included in the scope?

Yes, both the semiconductor and critical minerals investigations include derivative products, which are broadly defined.

• For critical minerals, derivative products cover "all goods that incorporate processed critical minerals as inputs. These goods include semi-finished goods (such as semiconductor wafers, anodes, and cathodes) as well as final products (such as permanent magnets, motors, electric vehicles, batteries, smartphones, microprocessors, radar systems, wind turbines and their components, and advanced optical devices).”
• For semiconductors, derivatives include "downstream products that contain semiconductors.”

Public Comments

NMMA will likely submit comments given the broad definitions of derivative products for both investigations.

• Semiconductors: Public comments are due May 7.
• Critical Minerals: No timetable for the investigation or comments has been set.

NMMA will continue monitoring developments and advocating for a nuanced approach to tariffs that keep the uniquely American recreational boating industry competitive at home and abroad.

Members with questions or information to help shape NMMA’s comments are encouraged to contact Clay Crabtree, NMMA's Senior Director of Public Policy, at [email protected].