On June 29, 2026, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of anthracite coal. For the purposes of this investigation, anthracite coal encompasses products classified under Harmonized Tariff Schedule of the United States (HTSUS) code 2701.11.0000 (Anthracite Coal) and 2701.12.0010 (Metallurgical Bituminous Coal). The scope of this investigation is primarily focused on these coal products that are considered critical materials for domestic steel production and industrial processes, including their role as derivative articles of steel for potential coverage under Section 232 tariffs.

Interested parties may submit written comments, data, analyses, or other information to the Office of Strategic Industries and Economic Security at Commerce’s Bureau of Industry and Security (BIS) no later than July 21, 2026. BIS is particularly interested in comments addressing:

  1. The current and projected demand for anthracite coal in the United States;
  2. The extent to which domestic production of anthracite coal can meet domestic demand;
  3. The role of foreign supply chains, particularly of major exporters, in meeting United States demand for anthracite coal;
  4. The concentration of U.S. imports of anthracite from a small number of suppliers or foreign nations and the associated risks;
  5. The impact of foreign government subsidies and predatory trade practices on the competitiveness of anthracite producers in the United States;
  6. The economic impact of artificially suppressed prices of anthracite due to unfair foreign trade practices and state-sponsored overproduction;
  7. The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of anthracite coal;
  8. The feasibility of increasing domestic capacity for anthracite coal production to reduce import reliance;
  9. The impact of current trade policies on domestic production of anthracite coal, and whether additional measures, including tariffs or quotas, are necessary to protect national security;
  10. The impact of the use or lack of use of anthracite coal on U.S. manufacturing employment;
  11. The potential for foreign control or exploitation of the anthracite coal supply chain;
  12. The future role of anthracite coal production of items essential to national security or in activities related to national security; and
  13. Any other relevant factors.

Comments must be submitted via the federal rulemaking portal at www.regulations.gov. The Docket ID for the request for public comments regarding this Section 232 investigation is BIS-2026-0298, and submitters must refer to XRIN 0694-XC165 in all comments.

In initiating this investigation, the Secretary of Commerce must, within 270 days, submit a report to the President with findings and recommendations on potential actions to mitigate any national security threats. While the Section 232 process allows for public hearings, it is unknown at this time whether Secretary of Commerce will direct such a process.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.