On May 11, 2020, the US Department of Commerce initiated an investigation into whether laminations for stacked cores for incorporation into transformers (8504.90.963), stacked and wound cores for incorporation into transformers (8504.90.9638; 8504.90.9642), electrical transformers (8504.21 – 8504.23, 8504.32 – 8504.34) and transformer regulators (9032.89.2000; 9032.89.4000) are being imported into the United States in quantities or under circumstances that threaten national security. The numbers in parenthesis are HTS Codes and “transformers” include both liquid and dry transformers with power handling capacities greater than 1 KVA. The investigation under Section 232 of the Trade Expansion Act of 1962, as amended, follows inquiries and requests from multiple members of Congress as well as industry stakeholders.

The Department of Commerce requested public comments on the investigation (please find further details here) on May 19, 2020. The deadline for filing initial comments is June 9, 2020 and the deadline for filing comments in rebuttal is June 19, 2020. Comments in rebuttal may only address issues raised in comments filed on or before June 9, 2020.

“The Department of Commerce will conduct a thorough, fair and transparent review to determine the effects on the national security from imports of laminations for stacked cores for incorporation into transformers, stacked and wound cores for incorporation into transformers, electrical transformers and transformer regulators,” said Secretary Ross.

According to the US Department of Commerce, transformers are part of the US energy infrastructure and an assured domestic supply of transformers and critical transformer components enables the United States to respond to large power disruptions affecting civilian populations, critical infrastructure and US defense industrial production capabilities.

The scope of the investigation includes the following (HTS codes):

1. Laminations for Stacked Cores for Incorporation into Transformers (8504.90.9634)
2. Stacked and Wound Cores for Incorporation into Transformers (8504.90.9638; 8504.90.9642)
3. Electrical Transformers (8504.21 – 8504.23, 8504.32 – 8504.34), i.e., “transformers (liquid and dry), above 1 KVA power handling capacity”
4. Transformer Regulators (9032.89.2000; 9032.89.4000).

Deadline for filing comments: June 9, 2020
Deadline for filing comments in rebuttal: June 19, 2020

Junko Suetomi has experience practicing law in Japan and the United States. Prior to joining Baker McKenzie, she worked in the WTO Dispute Settlement Division of the Ministry of Foreign Affairs’ Economics Bureau. She has also worked for a global law firm in Washington DC and New York, and served as a court-appointed defense attorney in many criminal cases. She has been a member of the Attorney’s Ethics Committee of the Osaka Bar Association and vice chair of the Human Rights Committee of the Tokyo Bar Association. She delivers lectures at Waseda University. She is recognized as a leading lawyer in her field by Chambers International and Chambers Asia, Best Lawyers, Who's Who Legal, and other ranking publications.


Takumi Hasegawa is a member of the Dispute Resolution Practice Group in the Firm's Tokyo office. Prior to joining Baker McKenzie, he worked for a maritime law firm with an emphasis on litigation and arbitration cases. Takumi's practice focuses on dispute resolution, including litigation and arbitration and corporate compliance matters related to regulatory issues, and internal investigations. He has particular expertise in healthcare regulatory compliance matters and has been seconded to the legal departments of multiple global pharmaceutical and medical device companies.