Trump Administration Imposes Section 232 Tariffs on Drones and Their Parts
Background
President Trump signed a Proclamation on August 13 to address the national security threat posed by imports of uncrewed aircraft systems (UAS or drones) and their parts and components. The Proclamation cited the findings of an investigation the U.S. Department of Commerce initiated in July 2025, pursuant to Section 232 of the Trade Expansion Act of 1962. The Proclamation introduces several measures intended to strengthen the domestic UAS industry and its supply chain, including:
- The imposition of a 100% ad valorem tariff on drones that either reach a certain size (i.e., a maximum takeoff weight of more than 25 kilograms) or possess thermal imaging capabilities. The same duty will likewise apply to these drones’ docking stations as well as certain critical components (see Annex I). These tariffs will take effect on September 3, 2026.
- Certain parts for heavy lift drones intended for agricultural and U.S. Department of War (DOW) purposes will be excluded from the tariff.
- The imposition of a 25% ad valorem tariff on smaller drones (i.e., a maximum takeoff weight of 25 kilograms or less) that lack capabilities that implicate national security (see Annex II). The same duty will also apply to these drones’ critical components (see Annex III). These tariffs will take effect on September 3, 2026 (except for Annex III products, where they will take effect on February 9, 2027).
- The imposition of a 15% ad valorem tariff on drones and their components from the European Union, Japan, Liechtenstein, the Republic of Korea, Switzerland, and Taiwan as well as a 10% ad valorem tariff on drones from the United Kingdom.
- To qualify for these reduced duty rates, importers must certify that substantially all hardware, software, and technology either originate in these countries or the United States.
- A directive to the Secretary of Commerce to establish an onshoring program for companies that intend to pursue new investments in the production of drones or their components.
- Applicable companies may submit onshoring plans that commit to build, refurbish, or expand a U.S. facility, with construction commencing before January 20, 2029. If the Secretary of Commerce approves the plan, the company may then import covered products for its supply chain, along with necessary production equipment, in volumes commensurate with the factory’s anticipated annual output – free of relevant Section 232 duties during the construction period.
- For any drones or components that the DOW approves for an exemption from the Federal Communications Commission’s Covered List within 20 days of the Proclamation’s signing (i.e., by September 2, 2026), these Section 232 duties will take effect on February 9, 2027.
Implications for the UAS Industry
Recent Executive actions concerning drones, notably Executive Order 14307, “Unleashing American Drone Dominance,” underscore a coordinated federal effort to strengthen the domestic industrial base as well as address emerging national security risks. Companies that depend upon foreign-sourced drones or critical components now confront a tiered duty structure that could materially raise landed costs. Moreover, given the staggered nature of these duties (i.e., the September 3, 2026 and February 9, 2027 effective dates), importers should map their supply chains against Annexes I, II, and III to determine which products fall within scope and when the corresponding duties take effect. Companies seeking reduced tariff rates for qualifying allied-country products must prepare to certify that substantially all hardware, software, and technology originate in those jurisdictions or the United States, a requirement that will demand both rigorous origin tracing and documentation.
Moving forward, the Proclamation creates opportunity for companies to reconfigure their sourcing and production strategies. The onshoring program, for instance, offers a meaningful incentive for companies willing to commit to constructing, refurbishing, or expanding domestic manufacturing capacity. Interested companies should proceed deliberately, as the project must commence before January 20, 2029, and the volume of duty-free imports will track each facility’s anticipated annual output. Meanwhile, firms unable to onshore in the near term should consider diversifying toward qualifying allied suppliers to capture the reduced rates, while remaining mindful that the Secretary of Commerce retains authority to expand the covered components “on a rolling basis.” Given this evolving landscape, companies should monitor further agency action as they position themselves to mitigate duty exposure and pursue available relief.
Wiley’s National Security, International Trade, and Strategic Competition & Supply Chain practices have unparalleled experience representing a broad range of U.S. and multinational clients in complex export control, sanctions, international trade, and supply chain matters. For more information on this Proclamation and any other international trade issues, please contact either of the attorneys listed on this alert.
Nate Moll, an International Trade Specialist at Wiley Rein LLP, contributed to this alert.
