NBAA Urges Members: Make Your Voice Heard on Tariff Impacts by June 3 Deadline
The National Business Aviation Association (NBAA) encourages its members and other business aviation stakeholders to weigh in on a U.S. Department of Commerce investigation to determine the impacts of imports of commercial aircraft, engines and parts on national security.
Commerce Secretary Howard Lutnick recently initiated the investigation under Section 232 of the Trade Expansion Act of 1962, specifically 15 CFR 705.4, addressing potential impacts of imports to national security and the nation’s economy.
The Commerce Department is taking public comments as part of its investigation; the deadline for comments is June 3, 2025.
Importantly, the May 28 ruling from the U.S. Court of International Trade, blocking President Trump’s tariffs imposed under the International Emergency Powers Act – such as the “Liberation Day” tariffs and the 25% tariffs on Canada and Mexico – does not impact the Section 232 investigation.
“A strong industrial workforce, healthy national economy and a safe national airspace system are vital to our national security,” said NBAA President and CEO Ed Bolen. “The U.S. leads the world in aerospace manufacturing, and has maintained the largest positive trade balance of any sector for several decades, thanks to 45 years of reciprocal tariff-free trade under the 1979 Agreement on Trade in Civil Aircraft.”
The U.S. aviation industry carries a $104 billion trade surplus, Bolen continued, supporting 9.4 million jobs, $1.8 trillion in total economic activity and contributing 4% of the U.S. gross domestic product.
Stakeholders are urged to use NBAA’s online Voter Voice resource to submit comments, data, analyses or other information to the Commerce Department, and the agency will acknowledge significant industry participation.
Comments should focus on how the import of aircraft, engines and parts has strengthened national security, primarily through the Agreement on Trade in Civil Aircraft, a reciprocal tariff-free trade agreement that has enabled a dominant U.S. manufacturing base, strong workforce and vibrant economy, but most importantly a bedrock foundation of safety regulation and oversight, which ensures that only FAA-approved or mutually recognized aircraft and parts are available for import and export. Implementing tariffs on aircraft, engines or parts will significantly undermine these benefits.
Possible focus areas for comments include:
- Detailing the negative impact of recently implemented tariffs on aircraft transactions, aircraft maintenance and flight operations
- Impacts such as cancelled or delayed orders for aircraft, engine, parts or services
- Possible relocation of manufacturing and MRO facilities or services; supply chain ramifications
- The loss of jobs, business and U.S. aerospace expertise
The best comments will include personal or company anecdotes about the impact or expected impact of tariffs. Comments will be public unless filed as “business confidential.”
“U.S. aerospace is a trade success story. As business aviation manufacturers, suppliers and companies adapt to this ever-changing environment, it’s imperative that we share our positive story and information about the trade agreement that enabled our success,” Bolen concluded.
Following the comment period, the commerce secretary will submit a report on the investigation findings and recommendations to the president. While Section 232 investigations under the Trump administration have resulted in the imposition of tariffs, the president may take non-trade related actions as well.
For more information about the investigation or the comment process, members should tune in to NBAA’s Emergency Town Hall webinar on Friday May, 30 at 11 a.m. (EDT). Visit NBAA’s website to register or learn more about the webinar.