February 20, 2025
UPDATE ON SECTION 232: ALUMINUM AND STEEL PRODUCTS
On February 10, 2025, President Trump issued two (2) Presidential Proclamations which impose, pursuant to Section 232 of the Trade Expansion Act of 1962, 25% additional tariffs on steel and aluminum products of all countries, effective March 12, 2025. The Section 232 Proclamations eliminate existing Section 232 country exemptions, product exclusions, and absolute and tariff-rate quota arrangements that were previously negotiated with certain countries, and increase the scope of covered steel and aluminum products subject to the additional tariffs.
Effective February 11, 2025, the product exclusion process will be terminated, meaning no new exclusions will be granted and any pending applications will be denied. Previously granted exclusions will remain in effect until their expiration date or until the allotted volume is imported — whichever happens first. General Approved Exclusions (GAEs) will continue to be valid until March 12, 2025.
Effective March 12, 2025, all steel and aluminum imports covered by the prior Section 232 actions — regardless of origin — will be subject to the 25% tariff. Countries that once benefitted from alternative tariff agreements — Australia, Canada, Mexico, South Korea, Brazil, Argentina, the EU, Japan, and the UK — will now face the same treatment as all other exporting countries.
Imports of derivative aluminum articles containing any primary aluminum smelted or cast in Russia will face an even higher 200% tariff.
The annexes are listed below:
STEEL
ALUMINUM
For steel products, there are 155 derivative items in chapter 73, which will face 25% tariffs, unless they are from Turkey; a dozen other items will only owe duties on the steel content in them, and those are either in chapter 84 or 94. The items in those chapters include bulldozer blades, parts of escalators and elevators, backhoe and front-loader attachments, plows, steel shelving, modular steel building units, brass lighting fixtures and other lighting fixtures. Only the steel content used in the manufacture of the derivative article will be subject to the tariffs.
For aluminum products, eighteen of the tariff lines are in Chapter 76, which means the entire value will be subject to the tariff; the other 104 are in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96, and only the aluminum content in those goods will face the tariffs.
Note that the Department of Commerce was given 90 days to advise that an adequate system is in place to “fully, efficiently and expediently process and collect the tariffs” for the covered articles. There will be public notification before the tariffs are due on the derivative items.
The proclamations direct CBP to impose maximum monetary penalties for misclassification of steel and aluminum articles and even suggest that CBP is not permitted to mitigate such penalties.
We will continue to monitor this and provide updates as they are available.
Please contact us if you have any questions about this or any other trade matter.
Effective February 11, 2025, the product exclusion process will be terminated, meaning no new exclusions will be granted and any pending applications will be denied. Previously granted exclusions will remain in effect until their expiration date or until the allotted volume is imported — whichever happens first. General Approved Exclusions (GAEs) will continue to be valid until March 12, 2025.
Effective March 12, 2025, all steel and aluminum imports covered by the prior Section 232 actions — regardless of origin — will be subject to the 25% tariff. Countries that once benefitted from alternative tariff agreements — Australia, Canada, Mexico, South Korea, Brazil, Argentina, the EU, Japan, and the UK — will now face the same treatment as all other exporting countries.
Imports of derivative aluminum articles containing any primary aluminum smelted or cast in Russia will face an even higher 200% tariff.
The annexes are listed below:
STEEL
ALUMINUM
For steel products, there are 155 derivative items in chapter 73, which will face 25% tariffs, unless they are from Turkey; a dozen other items will only owe duties on the steel content in them, and those are either in chapter 84 or 94. The items in those chapters include bulldozer blades, parts of escalators and elevators, backhoe and front-loader attachments, plows, steel shelving, modular steel building units, brass lighting fixtures and other lighting fixtures. Only the steel content used in the manufacture of the derivative article will be subject to the tariffs.
For aluminum products, eighteen of the tariff lines are in Chapter 76, which means the entire value will be subject to the tariff; the other 104 are in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96, and only the aluminum content in those goods will face the tariffs.
Note that the Department of Commerce was given 90 days to advise that an adequate system is in place to “fully, efficiently and expediently process and collect the tariffs” for the covered articles. There will be public notification before the tariffs are due on the derivative items.
The proclamations direct CBP to impose maximum monetary penalties for misclassification of steel and aluminum articles and even suggest that CBP is not permitted to mitigate such penalties.
We will continue to monitor this and provide updates as they are available.
Please contact us if you have any questions about this or any other trade matter.
