Increase in Steel and Aluminum Tariffs, Change to Stacking Order
On June 3, 2025, President Trump issued a proclamation doubling Section 232 tariffs on steel and aluminum imports from 25% to 50% ad valorem, effective 12:01 a.m. EDT Wednesday, June 4, 2025. The proclamation cites the need to “adjust the imports of steel and aluminum articles and their derivative articles so that such imports will not threaten to impair the national security,” and to “more effectively counter foreign countries that continue to offload low-priced, excess steel and aluminum in the United States market and thereby undercut the competitiveness of the United States steel and aluminum industries.”
Products from the United Kingdom will remain subject to the 25% rate under the U.S.-UK Economic Prosperity Deal. U.S. Customs and Border Protection (CBP) issued detailed implementation guidance introducing significant changes to duty calculations. For derivative steel products classified outside Chapter 73 and derivative aluminum products classified outside Chapter 76, the Section 232 tariffs apply to the metal content value, and the reciprocal tariff will apply to the non-metal value. This requires importers to report products on two separate entry lines when the metal content value differs from the total entered value. Products containing steel melted and poured in the United States qualify for a 0% duty rate on that content.
The proclamation also modifies the tariff stacking order under Executive Order 14289. CBP has emphasized strict compliance with the new reporting requirements, including accurate declaration of metal content values and proper country codes for steel melt/pour and aluminum smelt/cast locations. Russia-origin aluminum products continue facing 200% duties on the entire product value.
Quick takeaways from the proclamation and CBP guidance:
- Section 232 tariffs on steel and aluminum increase from 25% to 50% ad valorem (UK remains at 25%).
- For derivative products, Section 232 duties now apply to metal content value, and the reciprocal tariff will apply to the non-metal value.
- Products must be reported on two entry lines when metal content value differs from total entered value.
- Steel melted and poured in the United States qualifies for 0% duty rate on that content.
- Modified tariff stacking order: Articles subject to Section 232 steel/aluminum tariffs move “up” in priority
- Russia-origin aluminum continues to face 200% duties on entire product value.
- New reporting requirements include country codes for steel melt/pour and aluminum smelt/cast locations.
- Foreign Trade Zone products admitted under “privileged foreign status” before June 4 subject to prior rates.
- No drawback available on duties imposed under this proclamation.
- CBP will enforce strict compliance with new reporting and valuation requirements.
UPDATE: June 9, 2025
Today, CBP published CSMS #65289012 “UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products” and CSMS #65288754 “UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products”.
CBP also updated the 232 product lists for steel and aluminum.
Updated Steel and Steel Derivative Products HTS List
Updated Aluminum and Aluminum Derivative Products HTS List
Stay tuned for further updates.
