Section 232 of the Trade Expansion Act of 1962 (“Section 232”) authorizes the President to “adjust” imports—including through application of tariffs, quotas, tariff rate quotas, and license fees—where the Department of Commerce (“Commerce”) determines imports threaten to impair U.S. national security. Since February 2025, President Trump has invoked Section 232 to impose or modify tariffs on U.S. imports across a range of sectors. These include actions on imports of steel, aluminum, and copper; automobiles and auto parts; timber, lumber, and wood products; trucks, truck parts, and buses; critical minerals; semiconductors; and pharmaceuticals. Potential actions by the Trump administration are pending in six ongoing Section 232 investigations, and new Section 232 investigations are rumored to be forthcoming. This alert provides an overview of the Section 232 actions taken by the second Trump administration as of April 2026 and also addresses upcoming and possible future Section 232 actions.

Click here to read the full alert on cov.com.

Photo of Shara Aranoff Shara Aranoff

Shara helps clients navigate trade remedies, tariffs, and customs regulations in support of their U.S. and global market strategies.

Shara is the Chair of Covington’s International Trade Practice Group, and co-leads the Customs practice.

Drawing on her 20 years of service in the…

Shara helps clients navigate trade remedies, tariffs, and customs regulations in support of their U.S. and global market strategies.

Shara is the Chair of Covington’s International Trade Practice Group, and co-leads the Customs practice.

Drawing on her 20 years of service in the U.S. government, she develops legal and public policy strategies to assist clients engaging with the U.S. International Trade Commission (ITC), U.S. Customs and Border Protection (CBP), Congress, and the courts. In high-stakes antidumping and countervailing duty investigations, Shara helps global manufacturers, distributors, and retailers protect their access to the U.S. market. She assists technology, life sciences and manufacturing companies enforce and defend their intellectual property rights in cross-border Section 337 investigations. Chambers praises her for bringing “behind-the-curtain knowledge to the private sector” in proceedings before the ITC by leveraging her experience as a decision maker.

Shara also regularly advises clients in a wide range of industries on Customs compliance and tariff mitigation, including:

Providing legal opinions or seeking Customs rulings on classification, valuation, country of origin, and product marking/labelling.
Conducting internal compliance reviews, drafting compliance policies, and providing training.
Responding to CBP audits and inquiries and filing voluntary disclosures.
Developing strategies to reduce tariffs and take advantage of trusted trader programs.

Prior to joining the firm, Shara was a Commissioner and Chairman of the ITC, where she was a decision-maker in hundreds of Section 337, antidumping, countervailing duty, and safeguard investigations.

She previously served as Senior International Trade Counsel for Senator Max Baucus (D-MT) at the U.S. Senate Committee on Finance, where she was responsible for legislative and policy issues including Trade Promotion Authority; negotiations involving the World Trade Organization and free trade agreements; and trade remedy and customs laws. She was also an attorney-advisor in the Office of the General Counsel at the ITC, where she was lead counsel in litigation before the Court of Appeals for the Federal Circuit and the Court of International Trade.

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Photo of Marney Cheek Marney Cheek

Marney Cheek has advised companies, non-governmental organizations, and governments on high-stakes international disputes and legal strategy for more than 20 years.

Marney serves as both counsel and advocate before numerous international arbitral tribunals and courts, including the International Court of Justice, U.S. federal…

Marney Cheek has advised companies, non-governmental organizations, and governments on high-stakes international disputes and legal strategy for more than 20 years.

Marney serves as both counsel and advocate before numerous international arbitral tribunals and courts, including the International Court of Justice, U.S. federal court, and major arbitral institutions such as the AAA, ICSID, PCA, and SIAC. She represents clients in complex international commercial disputes, having successfully defended a client in a $1.8 billion claim filed by a collaboration partner. Marney serves as both counsel and arbitrator in numerous investment treaty arbitrations. She is an expert on public international law and currently represents the Government of Ukraine in its landmark cases before the International Court of Justice adverse to the Russian Federation, including Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation).

In addition to leading complex disputes, Marney routinely advises clients on public international law matters and issues arising under numerous multilateral treaties. Her pro bono work includes representation of Radio Free Europe/Radio Liberty, and she serves on the Steering Committee of Covington’s Wimmer Initiative, a pro bono program that focuses on protecting and advancing media freedom. She also is at the forefront of business and human rights disputes, having represented global labor unions in the first binding arbitration brought under a business and human rights compact, the Bangladesh Accord on Fire and Building Safety.

Drawing upon her experience as Associate General Counsel at the Office of the U.S. Trade Representative, Marney also routinely counsels clients on international trade matters and is a member of the roster of arbitrators for several U.S. free trade agreements.

Marney is a member of the Council on Foreign Relations and serves as a Vice President of the American Society of International Law. She is also a member of the Board of Directors of the Robert H. Jackson Center. She has previously taught investment law at Columbia University School of Law. She is recognized as an “extraordinarily thoughtful” and “creative” lawyer with a “wealth of knowledge” on international law matters in Chambers and Legal 500.

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Photo of Alexander Chinoy Alexander Chinoy

Alex Chinoy assists clients with the resolution of inbound U.S. trade disputes, appearing before a range of U.S. courts and agencies. He is an accomplished trade litigator who has represented clients at both the U.S. International Trade Commission (ITC) and the U.S. Department…

Alex Chinoy assists clients with the resolution of inbound U.S. trade disputes, appearing before a range of U.S. courts and agencies. He is an accomplished trade litigator who has represented clients at both the U.S. International Trade Commission (ITC) and the U.S. Department of Commerce (DOC) in antidumping (AD) and countervailing duty (CVD) investigations. He has also been involved in more than 30 Section 337 unfair import investigations before the ITC. He has appeared in a range of other trade enforcement and regulatory matters, including litigation at the Court of International Trade (CIT) and the Court of Appeals for the Federal Circuit (CAFC), involving actions against U.S. Customs and Border Protection (CBP), the DOC, and the ITC. 

Outside the courtroom, Alex assists clients with a range of CBP compliance and enforcement matters, including inter partes IP enforcement proceedings, 19 CFR 177 ruling requests, investigative inquiries including RASAs and audits, prior disclosures, penalty notice responses, development of corrective action plans, and tariff evaluation and mitigation counseling.

In addition to his litigation and customs work, Alex has been repeatedly recognized by Chambers for his work at the ITC, with sources noting he is “impressive beyond his years of practice.” Alex is a past President of the ITC Trial Lawyers Association, the leading bar association for Section 337 practitioners. He has hands-on experience with every phase of Section 337 investigations. He has participated in a dozen hearings at the ITC ranging from trials on violation to enforcement hearings and temporary relief proceedings. His experience spans every phase of 337 litigation, from pre-complaint counseling through appeal of final ITC determinations to the CAFC, with a particular focus on disputes and counseling involving CBP enforcement of ITC exclusion orders.

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Photo of Jay Smith Jay Smith

Jay Smith is a partner in the Washington office. He joined the firm after several years as a professor of political science and international affairs, during which he specialized in international trade policy and international dispute settlement. His practice in the International and…

Jay Smith is a partner in the Washington office. He joined the firm after several years as a professor of political science and international affairs, during which he specialized in international trade policy and international dispute settlement. His practice in the International and Litigation groups draws on this academic and policy experience.

He is currently helping clients develop and implement strategies to mitigate supply chain risks arising from U.S. trade actions. In addition, Jay regularly represents respondents in U.S. trade remedy proceedings and related litigation, helping to secure a number of negative injury determinations at the ITC in recent years. Jay also advises clients on the negotiation and enforcement of international treaty commitments under the WTO, bilateral and regional trade agreements such as the USMCA, and other international fora. Much of his policy work is at the intersection of trade and other areas, such as intellectual property, the environment, or labor rights.

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Photo of Arun Venkataraman Arun Venkataraman

Arun Venkataraman leverages 20 plus years of government and private sector experience to provide legal, policy, and strategic advice to clients on a range of international trade matters.

Arun joined the firm after serving in senior roles at the U.S. Department of Commerce.

Arun Venkataraman leverages 20 plus years of government and private sector experience to provide legal, policy, and strategic advice to clients on a range of international trade matters.

Arun joined the firm after serving in senior roles at the U.S. Department of Commerce. Most recently, he served as the Senate-confirmed Assistant Secretary of Commerce for Global Markets and Director General of the U.S. and Foreign Commercial Service at the International Trade Administration (ITA) from 2022-2025. Arun led the federal government’s efforts to expand commercial opportunities for U.S. firms overseas and foreign firms in the United States, including by facilitating deals between U.S. and foreign companies, improving commercial policy environments, resolving barriers to trade and investment, and negotiating governmental agreements to promote commercial partnerships. He also served as Counselor to the Secretary of Commerce, advising the Secretary on all aspects of foreign economic policy within the Department. In this role, Arun led negotiations with foreign governments on technology policy, as well as Section 232 steel and aluminum tariffs.

Before joining the Biden Administration, Arun was Senior Director, Global Government Engagement, at Visa. He developed and executed engagement strategy, in advocacy before the U.S. and foreign governments, as well as with trade associations, international organizations, and other stakeholder groups on a range of international policy issues including digital economy, trade, tax, and sanctions.

During the Obama Administration, Arun served as ITA’s first-ever Director of Policy, where he led efforts across the Commerce Department to remove global trade and investment barriers and strengthen the global competitiveness of U.S. industry, including in such markets as China and India. This included leading Department efforts to support Trans-Pacific Partnership (TPP) negotiations, pass Trade Promotion Authority (TPA) legislation, and secure improvements in China’s competition law and semiconductor policies.

Arun also served in the Office of the U.S. Trade Representative (USTR) as the Director for India, where he led the development and implementation of U.S.-India trade policy, for which he received the agency’s Kelly Award for outstanding performance and extraordinary leadership. He also served as USTR’s Associate General Counsel, representing the United States in litigation before the World Trade Organization (WTO) and in bilateral and multilateral negotiations on international trade agreements.

Prior to USTR, Arun was a Legal Officer in the Appellate Body Secretariat at the WTO, where he advised on appeals in litigation between countries under WTO rules. He also served as a Law Clerk for Judge Jane A. Restani at the U.S. Court of International Trade.

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Photo of Vivian Choi Vivian Choi

Vivian (Sooan) Choi is special counsel in the Washington office who advises clients on international trade matters. Previously, Vivian has worked with the World Trade Organization and the Republic of Korea’s trade ministry in various roles.

Vivian also has experience representing companies in…

Vivian (Sooan) Choi is special counsel in the Washington office who advises clients on international trade matters. Previously, Vivian has worked with the World Trade Organization and the Republic of Korea’s trade ministry in various roles.

Vivian also has experience representing companies in a broad range of corporate transactions.

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Photo of Minwoo Kim Minwoo Kim

Minwoo Kim acts as counsel and advisor to states and corporate clients on international trade policy, public international law, and complex cross-border disputes.

In his disputes practice, Minwoo has handled high-stakes commercial, investor-state, and state-to-state matters involving multinational parties, diverse industries, and a…

Minwoo Kim acts as counsel and advisor to states and corporate clients on international trade policy, public international law, and complex cross-border disputes.

In his disputes practice, Minwoo has handled high-stakes commercial, investor-state, and state-to-state matters involving multinational parties, diverse industries, and a range of procedural regimes. He is a Professorial Lecturer in Law at George Washington University School of Law (Arbitration) and serves as an international arbitrator.

In his trade practice, Minwoo advises companies, trade associations, and governments on U.S. trade and tariff measures, as well as responsive measures by foreign governments. He counsels clients on the interpretation and strategic use of international economic agreements—including free trade agreements (FTAs), bilateral investment treaties (BITs), and agreements within the World Trade Organization framework—to address market barriers and resolve disputes.

A native of Korea, he regularly advises Korean companies and government entities, as well as multinational clients with business interests in Korea, on cross-border regulatory, trade, investment, and dispute matters.

Prior to joining the firm, Minwoo was a judicial intern for Hon. Rudolph Contreras, U.S. District Court for the District of Columbia, a legal intern at the Integrity Vice Presidency, the World Bank, and an intern at the National Assembly of Korea, the Foreign Affairs and Unification Committee. He also maintains an active pro bono practice.

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Photo of Kate McNulty Kate McNulty

Kate McNulty advises U.S. and international clients on a range of complex international trade issues, dynamic U.S. and global tariff matters, and related trade compliance questions, including tariff stacking. She provides legal, policy, and strategic advice to companies, trade associations, and governments on…

Kate McNulty advises U.S. and international clients on a range of complex international trade issues, dynamic U.S. and global tariff matters, and related trade compliance questions, including tariff stacking. She provides legal, policy, and strategic advice to companies, trade associations, and governments on international economic policy matters, and assists clients in navigating geopolitical risk. She advises clients on the negotiation and enforcement of international trade agreements, including enforcement proceedings arising under the facility-specific rapid response labor mechanism of the USMCA.

Kate regularly represents clients before U.S. agencies such as the Office of the U.S. Trade Representative (USTR) and the U.S. Department of Commerce, including in proceedings arising under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. She also litigates before the U.S. Court of International Trade and represents clients in antidumping and countervailing duty (AD/CVD) proceedings.

Prior to joining Covington, Kate held various positions in the U.S. government. Most recently, Kate served in the Office of Multilateral Trade Affairs at the U.S. Department of State from 2009 to 2018, where she managed trade enforcement matters for the Department—including U.S. government actions under Section 301 and Section 232—and also participated in the negotiation of international trade agreements on behalf of the U.S. government.

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Photo of Ray LaMotta Ray LaMotta

Ray LaMotta is an associate in the firm’s Washington, DC office and a member of the firm’s International Trade and CFIUS Practice Groups. Ray advises clients on the array of complex U.S. regulatory issues impacting cross-border transactions and the movement of goods. His…

Ray LaMotta is an associate in the firm’s Washington, DC office and a member of the firm’s International Trade and CFIUS Practice Groups. Ray advises clients on the array of complex U.S. regulatory issues impacting cross-border transactions and the movement of goods. His International Trade practice focuses on U.S. Customs and Border Protection (CBP) matters, including tariff classification, valuation, origin, and import compliance reviews. Ray also counsels clients on the national security review process administered by the Committee on Foreign Investment in the United States (CFIUS) for foreign direct investment, mergers, and acquisitions, including the development of compliance programs and mitigation agreements.

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Photo of Julia Shults Julia Shults

Julia Shults is an associate in the firm’s International Trade Practice Group in the Washington, DC office. Julia represents clients in complex antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce and the International Trade Commission (ITC). She also…

Julia Shults is an associate in the firm’s International Trade Practice Group in the Washington, DC office. Julia represents clients in complex antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce and the International Trade Commission (ITC). She also advises clients on a variety of trade policy and customs compliance matters, including on compliance issues related to tariff classification, country of origin, valuation, and tariff evaluation and mitigation. As part of her practice, Julia also litigates international trade issues before the U.S. Court of International Trade (CIT).

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