Expanded Section 232 Tariffs on Steel and Aluminum, Including Derivatives, Now in Effect
Effective March 12, 2025, the Section 232 tariffs on steel and aluminum imports, including “derivative products,” are all in place at 25% ad valorem (See Presidential proclamations 10896 and 10895, signed by President Trump on February 10, 2025).
Affected articles of steel and aluminum are classifiable in Chapters 73 (steel) and 76 (aluminum). The newly added derivative and downstream products are classifiable primarily under Chapters 84, 85, and 94 (steel) and Chapters 66, 83, 84, 85, 87, 88, 90, 94, 95, and 96 (aluminum). Each affected classification has been assigned a partner classification in Chapter 99 that captures the additional tariffs. The Department of Commerce has also been tasked with reviewing additional categories of derivative Steel/Aluminum products, upon request from U.S. industries, that may be added in the future.
To ensure the tariffs are imposed uniformly across all imports of affected articles, all previously granted General Approved Exclusions (“GAE”) have been revoked, effective March 12, 2025. Similarly, any active product-specific 232 exclusion will expire on the earlier of its scheduled expiration date or when the exclusion quantity limits are reached. The U.S. government is not accepting new exclusion requests, and pending applications will be denied. Additionally, country-specific exemptions and quotas nations have been rescinded. No new exemption procedures have been announced.
CBP issued updated guidance on steel and aluminum imports through CSMS bulletins on March 7, and March 11, 2025, outlining new classification and reporting requirements. Importers must keep abreast of their HTSUS classifications, be aware of the country of melt and pour (steel) and country of smelt (aluminum), and accurately calculate the value of non-U.S. steel/aluminum in derivative products.
CBP has made it clear that non-compliance with the revised classifications and duty requirements will lead to enforcement actions. Importers should carefully review the updated classifications, assess their tariff obligations, and adjust their supply chain strategies accordingly.
Stay tuned for further updates.
