US opens section 232 investigation on lumber/timber imports
Date of publication: March 7th, 2025
On March 1, 2025, President Trump issued an Executive Order (EO) directing the US Department of Commerce to investigate potential national security risks of lumber and timber imports, which could eventually lead to the imposition of tariffs on all lumber and timber imports. The Bureau of Industry and Security (BIS) will conduct the investigation under Section 232 of the Trade Expansion Act of 1962, a law that empowers the president to restrict imports of products that are found to threaten to impair national security.
The President stated in the EO that the 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. Although “dumping” is specifically mentioned in the EO, Section 232 is being applied here versus AD/CVD approach. Nearly half of US lumber imports come from Canada.
The wood products industry, composed of timber, lumber, and derivative products (such as paper products, furniture, and cabinetry) is deemed a critical manufacturing industry essential to the national security, economic strength, and industrial resilience of the United States and plays a vital role in key downstream civilian industries, including construction, as well as being a key input for the military.
President Trump has stated the current United States softwood lumber industry has the practical production capacity to supply 95 percent of the United States’ 2024 softwood consumption via its ample timber resources.
The goal is to reduce dependency of foreign sources and ensure a reliable domestic timber/lumber supply.
Next steps
The Section 232 investigation requires Commerce, in consultation with the Secretary of Defense and others, to evaluate the national security risks from the import of timber, lumber, and their derivative products. As part of its investigation, Commerce will consider, among other things:
- the current and projected demand for timber and lumber in the United States;
- the extent to which domestic production of timber and lumber can meet domestic demand;
- the role of foreign supply chains, particularly of major exporters, in meeting United States timber and lumber demand;
- the impact of foreign government subsidies and predatory trade practices on United States timber, lumber, and derivative product industry competitiveness;
- the feasibility of increasing domestic timber and lumber capacity to reduce imports; and
- 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.
As is standard with these investigations, BIS typically will gather public comments and hold hearings, providing opportunities for stakeholders to share input on the investigation. BIS will provide more information about its plans for the investigation in a future Federal Register notice.
The BIS investigation will take up to 270 days to complete (November 26, 2025), at which point a report must be submitted to the President with findings. Upon receiving BIS’ determination, the President can choose to take action to mitigate threats identified by the imports of the article or its derivatives – recommended actions to mitigate such threats could include potential tariffs, export controls, or incentives to increase domestic production.
Related executive order on immediate expansion of american timber production
On March 1, 2025, President Trump issued a second Executive Order (EO) related to timber production. This EO points out the critical impact of the wood products industry on the U.S. economy, as well as the role the industry plays in forest management and wildlife risk reduction, however notes that existing federal policies have prevented full utilization of resources and made the US more reliant on imports.
The EO directs relevant agencies to eliminate undue delays in permitting processes related to timber production and take steps to eliminate or revise agency actions that impose an undue burden on timber production.
The EO also calls out specific actions to review, revise, and/or eliminate policies, regulations, and other agency actions, including:
- By March 31, 2025, the Secretaries of the Interior and Agriculture must issue “new or updated guidance regarding tools to facilitate increased timber production and sound forest management, reduce time to deliver timber, and decrease timber supply uncertainty.”
- By April 30, 2025, the Secretaries of the Interior and Commerce must complete a strategy to improve the speed of approving forestry projects that undergo consultation pursuant to the Endangered Species Act (ESA).
- By May 30, 2025, the Secretaries of the Interior and Agriculture must submit to the President a plan identifying a target for the annual amount of timber per year to be offered for sale over the next four years from federal lands.
- By August 28, 2025, the Secretaries of the Interior and Agriculture must consider and, if appropriate, adopt categorical exclusions to comply with the National Environmental Policy Act and reduce the length and associated costs related to administrative approvals for timber production, forest management, and wildfire risk reduction treatments.
- By December 6, 2025, the Secretary of the Interior must consider and, if appropriate, establish a new categorical exclusion for timber thinning and reestablish a categorical exclusion for timber salvage activities.
- The Endangered Species Committee must, “to the maximum extent permissible under applicable law,” use the ESA regulations on consultations in emergencies to facilitate timber production and submit a report to the President that identifies obstacles to domestic timber production infrastructure resulting from the ESA and recommends improvements.
Conclusion
Companies would be wise to review their product database to identify products and suppliers that fall within the scope of the investigation. Given the tendency for the Trump Administration to impose tariffs under national security authorizations, scenario planning to determine potential impact and consider alternate options for sourcing would be wise.
To learn more about how the ONESOURCE Global Trade suite of tools and services can help businesses analyze potential impacts, explore alternative sourcing options, and optimize their trade operations to mitigate risks and capitalize on potential advantages, please contact your Account Manager or Client Services Manager.