Recently, the White House issued Executive Orders (EO) announcing an increase in steel and aluminum tariffs to 25% set to go into effect March 12, 2025. On February 10, the EO was published in the Federal Register and revised on March 5, 2025. In that revision the Commerce Department expanded the products in Annex 1 covered by this action for steel and aluminum.
Overview of changes
Modifications and additions being made to the Section 232 tariffs, originally implemented in 2018, include changes to existing exemptions, quotas, and exclusions, as well as the specific products.
Increased or adjusted tariffs
This revision increases tariffs for iron and steel articles listed under Chapter 72 and 73. Aluminum articles in Chapter 76 will be increased from 10% to 25%. The specific chapter heading and subheadings affected are listed in Annex 1 of Federal Register notices from March 5th.
Targeted steel and aluminum derivatives
New tariffs are being applied to specific iron, steel and aluminum derivative products (identified by HTS numbers in Annex 1 of the linked Federal Register notice). The 25% Section 232 duty will be applied to the value of the metal portion of these derivative items. The notice instructs importers of iron, steel and aluminum derivative articles to provide “any information necessary to identify the steel or aluminum content of the imported article.”
Regarding steel and aluminum derivatives, products identified in subheading (n) for steel and subheading (k) for aluminum, will not go into effect March 12th per section A of each Annex 1. Those specific subdivisions will be effective upon public notification of the Secretary of Commerce.
The 25% tariff does not apply to derivative steel articles processed in another country from steel articles that were melted and poured in the United States. If this applies to your product, you will want to instruct your supplier to notate your invoice to include language that shows the product was “melted or poured in the United States”. This information should also be outlined on your Mill Test Certificate (MTC). The same scenario is true for aluminum, if your aluminum article is cast and smelt in the United States, these tariffs do not apply.
Removal of exemptions and quotas
Countries previously holding an alternative agreement including Argentina, Australia, Canada, Mexico, the United Kingdom and the European Union (EU) are now subject to the 25% tariff.
All tariff-rate quotas (TRQ) (EU, Japan and the UK) and absolute quotas (Argentina, South Korea and Brazil) are no longer applicable.
Elimination of exclusions
The process for requesting product exclusions terminated on February 10, 2025, and any granted exclusions will remain in effect until their expiration date or until their excluded volume is imported, whichever comes first. All general approved exclusions (GAE’s) shall be ineffective as of March 12, 2025.
It's important to note that these changes do not mean a doubling of existing 232 tariffs. For example, items already subject to a 25% steel tariff will not have an additional 25% added. Instead, the changes involve removing exemptions and exclusions, increasing the aluminum tariff, and adding targeted tariffs on specific derivative products.
Keep in mind, imports of some Russian aluminum articles remain at 200% while imports of Turkish articles remain at 25%.
Best practices for shippers moving forward
Identify your impact
Review Annex 1 of each notice to determine if your imported commodities are affected by this change. Check with your customs broker to assist you with this analysis.
Update product database
Clearly communicate with your customs broker what products qualify and should be assessed the iron, steel and aluminum tariffs.
Confirm tariff classification
Confirm you have the appropriate harmonized tariff classification (HTS) for your product. If you are currently classifying a product in chapters 72, 73, 76 or any derivative chapters, you will want to validate your HTS number.
Review commercial documentation
Commodity descriptions should be clear and specific on the commercial invoice and packing list. For example, if you’re importing a metal chair the commercial invoice should clearly state “does not contain steel” or “does not contain aluminum”, as applicable.
Ensure you have the correct certifications
A Mill certificate is required for the importation of steel articles which will include the country of melt and the country of pour. Additionally, an aluminum certificate of analysis is required to import aluminum articles which will outline the primary and secondary country of smelt and the country of cast. Ensure that these documents are available from your supplier prior to arrival of the goods in the United States. You can review CBP requirements and definitions for aluminum smelt and cast articles here.
Understand the nuances of these adjusted tariffs
For example, when importing iron, steel or aluminum the percentage of that content is only needed for HTS outside of chapter 72, 73 and 76. And when it comes to aluminum articles, if an HTS code is only listed in the aluminum annex and not in the steel annex, you do not need to report the percentage of steel in those parts.
Also, keep in mind that utilizing a Chapter 98 tariff will be subject to the 25% tariff under Section 232 if the import article is steel or aluminum
Know your options
In relation to free trade agreements, the importer will continue to receive savings from the free trade agreement or preference program if they meet eligibility requirements; however, the product will still be subject to the 25% steel or aluminum tariff. Additionally, unlike some other tariffs, these tariffs are not eligible for drawback. Connect with your customs broker to explore other cost mitigation strategies for your shipments.
We understand these changes can be complex, but we’re here to help you navigate them. Connect with our team to see how these changes may impact your business and review the FAQ on our Trade & Tariff Insights page for more answers to your top questions.
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