NAMM and Several Members Call for Exemptions on Potential Timber, Lumber Action

April 15, 2025

On March 31, 2025, NAMM filed comments to the Federal Register in response to the March 1 Executive Order tasking the Secretary of Commerce to investigate whether there is a connection between importing timber and lumber and threats to national security. 

Under Section 232 of the Trade Expansion Act of 1962, President Trump gave the Department of Commerce 270 days from the March 1 order to provide a determination on whether importing timber and lumber threatens national security, and, if so, to provide recommendations for mitigating the threat through tariffs or other restrictions.

NAMM put out a call for impacted members to file impact statements to the Federal Register by the April 1 deadline. Several members filed their concerns, with the overwhelming majority requesting exemptions for tonewoods used to manufacture instruments in the U.S. that cannot be sourced here.

Though the Department of Commerce has until December 1, 2025, to make its recommendations it is expected that they will expedite both the results of the study and their recommendations. NAMM is watching this very closely and will provide timely updates.

March 18, 2025

In a March 1 Executive Order, the Secretary of Commerce was tasked by President Donald Trump with launching an investigation under Section 232 of the Trade Expansion Act of 1962 to assess the impact of importing timber (unprocessed woods) and lumber (processed woods) on national security.  

NAMM member companies that manufacture products in the United States using imported wood that cannot be sourced within the U.S. are encouraged to submit comments on the impact that tariffs or other restrictive measures would have on their businesses via the Federal Register by the April 1 deadline. According to instructions in the Federal Register, U.S. manufacturers are urged to “submit written comments, data, analyses, or information pertinent to this investigation to the Office of Strategic Industries and Economic Security, U.S. Department of Commerce (“the Department”), no later than April 1, 2025.”

The investigation will examine the following factors, so comments submitted to the Federal Register need to speak to these criteria:

1. Current and Projected Demand: Evaluating both current and future needs for timber and lumber in the U.S.
2. Domestic Production Capacity: Assessing whether domestic producers can meet this demand.
3. Role of Foreign Supply Chains: Understanding how foreign suppliers meet U.S. demand and the implications of their presence.
4. Impact of Foreign Subsidies: Analyzing how foreign government actions affect the competitiveness of the U.S. industry.
5. Capacity Expansion Feasibility: Exploring the potential for increasing domestic lumber production to mitigate reliance on imports.
6. Trade Policy Effects: Considering the impact of existing trade policies and whether additional measures, such as tariffs or quotas, are warranted.

Departments of Commerce and Defense to Make Recommendations

The Secretary of Commerce, in collaboration with the Department of Defense and other relevant agencies will evaluate possible national security risks associated with the importing of unprocessed and processed woods. Within 270 days of the order, issued on March 1, 2025, a comprehensive report will outline the Departments’ findings. This report will include recommended actions to mitigate risks and suggested policy changes, including potential tariffs, export controls or incentives to increase domestic production through permitting reforms and other means.

Though the deadline for recommendations is November 26, 2025, experts expect that the Departments of Commerce and Defense will speed up the investigation to provide recommendations as early as the summer.