Section 232: robotics and wind turbines go to talks

Two Section 232 proclamations direct Commerce and the USTR to negotiate with trading partners instead of imposing new tariffs. Proclamation 11077 of October 28, 2026 covers robotics, industrial machinery, and their parts and components (FR Doc. 2026-22385; 91 FR 69199, published November 2, 2026). Proclamation 11074 of October 22, 2026 covers wind turbines and their parts and components (FR Doc. 2026-22049; 91 FR 68001, published October 28, 2026). Neither proclamation imposes a new tariff, quota, or fee.

No new Section 232 duty in either proclamation. Negotiations first; 180-day updates by our count April 26, 2027 (robotics) and April 20, 2027 (wind).

What Commerce found

Both follow investigations under section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862). In each, the Secretary of Commerce found that the covered imports threaten to impair national security, and the President concurred.

For robotics and industrial machinery, the proclamation attributes to the Secretary that these products support defense systems and critical infrastructure and generate substantial economic value, including approximately $7.1 trillion in shipments of manufactured goods in 2024 and about $86 billion of equipment produced in 2024. The Secretary also found U.S. reliance on foreign imports, cybersecurity risks from certain foreign-sourced systems, and insufficient domestic capacity relative to national security needs.

For wind turbines, the Secretary found intermittency and grid burdens, cybersecurity vulnerabilities (including remote-access risks tied to foreign-produced inverters), radar interference, and rising import reliance for components and subcomponents. The wind proclamation notes that certain wind turbine components made of significant amounts of aluminum, steel, or copper are already subject to tariffs under Proclamations 9704, 9705, and 10962, as amended, and states that nothing in Proclamation 11074 modifies those or any other Section 232 tariffs.

Negotiations, not new duties

In both proclamations the President directs the Secretary and the USTR to jointly pursue or continue negotiations of agreements with trading partners they deem appropriate, and to update the President within 180 days of the proclamation. By our count that is April 26, 2027 for robotics and industrial machinery, and April 20, 2027 for wind turbines. The Secretary continues monitoring imports.

The robotics proclamation states that depending on the status or outcome of negotiations, the President may consider alternative remedies, including imposing or modifying tariffs, duties, quotas, and fees, and establishing a program to incentivize new investment in U.S. production. Section 232(c)(3)(A) lets the President take other actions if an agreement is not entered into within 180 days, is not carried out, or is ineffective. Neither proclamation predicts tariffs; do not treat negotiations as a rate change.

Action items

• Map exposure in robotics, industrial machinery, wind turbines, and related parts and components (country of origin and supplier).
• Watch for the 180-day updates and any later proclamation that actually changes rates or other remedies.
• Keep entry, commercial invoice, and classification records for these product groups; existing Section 232 duties on aluminum, steel, or copper wind components remain as previously imposed.

These two proclamations impose no new duty, so there is no new duty to recover. Existing Section 232 duties are unchanged by these actions. Ordinary customs duties on qualifying entries can still be drawback-eligible when merchandise is exported or destroyed (or used to manufacture exported goods) and the claim otherwise qualifies (how to file a duty drawback claim).

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.