White House Pursues Trade Talks on Robotics and Machinery, Holds Off on Tariffs

On October 28, 2026, President Donald Trump issued a proclamation concluding that imports of robotics, industrial machinery, and their parts and components threaten to impair the national security of the United States. The President directed the Secretary of Commerce and the U.S. Trade Representative (USTR) to jointly pursue negotiations with foreign trading partners. This is one of several regulatory actions taken in the past two years affecting the robotics sector. We review the key highlights below.

What’s the concern?

After an investigation under Section 232 of the Trade Expansion Act of 1962, the Secretary of Commerce (Secretary) concluded that imports of robotics and industrial machinery, and their parts and components, threaten to impair national security of the United States.

The Secretary’s report concluded that robotics or industrial machinery are essential to modern defense systems, critical infrastructure, and modern manufacturing. The Secretary further found that U.S. industry does not produce enough robotics, industrial machinery, and their components to meet national security needs, and U.S. reliance on foreign imports threatens the long-term competitiveness of the United States. Finally, the Secretary found, imports from certain foreign entities pose unique cybersecurity risks.

What did the President order?

In his Proclamation, the President adopted the Secretary’s findings that imports of robotics and industrial machinery, and their parts and components, threaten to impair U.S. national security. Section 232 provides the President with several options, including the imposition of tariffs. However, rather than impose tariffs, the President opted to direct the Secretary and the USTR to jointly pursue negotiations with foreign partners to address the threatened impairment.

This is the third time this year the President has opted for negotiations instead of tariffs following a Section 232 investigation (the other two involved (a) commercial aircraft, jet engines, and aircraft and engine parts and (b) wind turbines and their parts and components). In contrast, the President has in the last 18 months decided to impose Section 232 tariffs on imports of polysilicon, copper, and drones.

Does this mean that no tariffs will be imposed?

Not necessarily. The Secretary and USTR must provide a report to the President within 180 days, at which time the President may consider alternative remedies, including imposing or modifying tariffs.

What countries are being targeted?

The Proclamation directs the Secretary and USTR to begin negotiations with “jointly pursue negotiations of agreements or continue any current negotiations of agreements … with any foreign trading partner the Secretary and the Trade Representative deem appropriate.” According to the Council on Foreign Relations, “[m]ost U.S. imports of industrial robots and machinery come from allies — Canada, Germany, Italy, and Japan supply half of all imports. China ships 8 percent.”

Other Regulatory Actions Affecting Robotics

The Section 232 investigation into robotics, industrial machinery, and their components is one of several regulatory actions in recent years focused on the robotics sector.

In July 2026, the Federal Communications Commission (FCC) determined that foreign-produced advanced robotic devices pose an unacceptable national security risk, adding a category to its Covered List. The FCC action, unlike the October 28 presidential proclamation, had immediate policy consequences. Because equipment on the Covered List cannot normally receive an FCC equipment authorization, the listing bars new foreign-manufactured models of covered robots — including humanoids, quadrupeds, autonomous mobile robots, and other mobile devices — from being imported, marketed, or sold in the United States absent a Conditional Approval from the Department of Defense. See Sidley Update on the FCC determination here.

Additionally, the Department of the Treasury Outbound Investment Security Program, which became effective in January 2025, requires notification of certain U.S. person investments into Chinese companies that develop an AI system intended to be used for the control of robotics systems. Last week, Treasury proposed an updated rule that would more broadly prohibit U.S. investments into Chinese companies that develop AI systems, regardless of end use. See Sidley Update on the proposed outbound rule here.