# Section 232 Robotics and Industrial Machinery: Negotiations Instead of Tariffs

Trade Alert · November 2, 2026 · Lighthill PC

Commerce and USTR will negotiate with trading partners, with an update due within 180 days; tariffs, quotas and fees remain possible.

On October 28, 2026, President Trump signed a [proclamation](https://www.whitehouse.gov/presidential-actions/2026/10/adjusting-imports-of-robotics-industrial-machinery-and-their-parts-and-components-into-the-united-states/) under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862) concurring in the Secretary of Commerce’s finding that robotics, industrial machinery, and their parts and components are being imported “in such quantities and under such circumstances as to threaten to impair the national security.” As with the [wind turbines proclamation](https://www.whitehouse.gov/presidential-actions/2026/10/adjusting-imports-of-wind-turbines-and-their-parts-and-components-into-the-united-states/) of October 22, the President did not impose tariffs. 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:

- robotics and industrial machinery are critical to defense production and to all 16 critical infrastructure sectors

- the United States relies on imports for most types of robotics and industrial machinery and their components, and the value of those imports has increased over the last decade and is projected to keep growing

- robotics and industrial machinery from “certain foreign entities” pose cybersecurity and safety risks because they are integrated into manufacturing and defense systems and routinely process and store sensitive data

- domestic production falls short of national security needs

### 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 from time to time, with at least one update within 180 days of October 28, 2026, which falls on or about April 26, 2027.

- **Monitoring.** Commerce will continue to monitor imports and inform the President of circumstances that may indicate the need for further action.

- **Possible further action.** Depending on the negotiations, the President “may consider alternative remedies in the future, including imposing or modifying tariffs, duties, quotas, and fees,” and a program to incentivize new U.S. investment in production of robotics, industrial machinery and their components. The proclamation notes that Section 232(c)(3)(A) permits other action if an agreement is not entered into within 180 days, is not carried out, or is ineffective.

The proclamation does not define the products covered by HTSUS classification, identify the trading partners to be engaged, or specify the “foreign entities” of concern.

### Immediate Considerations

In practical terms, the proclamation does not change duties on robotics or industrial machinery today, and existing duties, including the Section 232 metals duties, continue to apply. Importers and users of industrial robots, machine tools, automation equipment and related parts should treat the 180-day negotiating period as a window before possible tariffs, quotas or fees. They should account for that risk in capital-equipment purchasing and long-term supply contracts. Because the findings emphasize cybersecurity risks from certain foreign sources, companies sourcing connected equipment from countries of concern may also face non-tariff measures.

Please contact us should you wish to discuss your exposure or engagement in the negotiations.

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This alert is provided by Lighthill PC for general informational purposes only. It is not legal advice and does not create an attorney-client relationship. Developments described here may have changed since the date of publication.

URL: https://www.lighthill.law/alerts/2026-11-02-section-232-robotics-and-industrial-machinery-negotiations-instead