On October 22, 2026, President Trump signed a proclamation under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862) concurring in the Secretary of Commerce’s finding that wind turbines and their components and subcomponents are being imported into the United States “under such circumstances as to threaten to impair the national security.” The President did not impose new tariffs. Instead, he directed the Secretary of Commerce and the U.S. Trade Representative (USTR) to negotiate agreements with foreign trading partners to address the threat.
The Secretary’s findings
As summarized in the proclamation, the Secretary found that:
- wind energy is intermittent and burdens the U.S. electrical grid
- networked inverters used in wind farms, particularly imported inverters, present cybersecurity vulnerabilities that could permit remote access and power disruption
- wind turbines can interfere with radar used for air traffic control, weather forecasting, homeland security and national defense
- U.S. reliance on imported wind turbine components and subcomponents has increased over the last decade, while domestic capacity for certain products, such as blades, has not meaningfully increased
Plan of action
- Negotiations. Commerce and USTR are to pursue, or continue, negotiations of agreements with any trading partners they deem appropriate.
- 180-day update. Commerce and USTR must update the President on the negotiations from time to time, with at least one update within 180 days of October 22, 2026, which falls on or about April 20, 2027.
- Monitoring. Commerce will continue to monitor imports and advise the President of any circumstances that may indicate the need for further action.
- Possible further action. The proclamation states that the President “may consider alternative remedies in the future” depending on the negotiations. It also notes that Section 232(c)(3)(A) permits other action, including tariffs, if an agreement is not entered into within 180 days or is not carried out or is ineffective.
Existing duties unchanged
The proclamation expressly does not modify the Section 232 duties on steel (Proclamation 9705), aluminum (Proclamation 9704) and copper (Proclamation 10962), or any other Section 232 tariff. The proclamation notes that certain wind turbine components and subcomponents made of significant amounts of those metals are already subject to those duties.
Immediate Considerations
In practical terms, the proclamation does not change duties on wind turbine imports today. Developers, OEMs and importers of wind turbines, towers, blades, nacelles, inverters and related parts should treat the 180-day negotiating period as a window before possible tariff action, and should factor that risk into procurement and project contracts. The proclamation does not specify which trading partners will be engaged or what any agreement would require. Companies with significant sourcing from a particular country may wish to monitor or engage in those discussions.
Please contact us should you wish to discuss your exposure under this or the existing Section 232 metals actions.