On February 10, 2025, President Trump announced the reinstatement of a 25% tariff on steel imports and an increase of aluminum tariffs (fact sheet) from 10% to 25% including products of Canada, Mexico, and China. This action aims to protect U.S. steel and aluminum industries from unfair trade practices and global overcapacity. The new tariffs are imposed by virtue of the elimination of quota arrangements, exemptions, and product exclusions that are removed on March 12, 2025. This affects imports of steel and steel derivatives from Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korea, the U.K., Ukraine and the EU. These measures are in follow-up to prior tariffs imposed pursuant to Section 232 of the Trade Expansion Act of 1962.
The new tariffs are being imposed with several key changes:
There is an elimination of all Section 232 country exemptions and quota agreements.
Only steel and aluminum products that are melted and poured in the U.S. will be exempt.
All general product exclusions will end March 12. Other product exclusions will remain in effect until they expire or until the excluded product volume is imported. No further exclusions may be considered.
Tariffs will now apply to key downstream products, including finished goods like extrusions and slabs. These tariffs won't take effect until notification from the Commerce Department that “adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.”
Some of the downstream products potentially affected include:
Steel Extrusions – These are processed steel products used in construction, automotive, and manufacturing sectors.
Aluminum Extrusions – Similarly, aluminum extrusions used in construction, aerospace, and other industries will be subject to tariffs.
Steel Slabs – Semi-finished steel products like slabs, which are used in producing finished goods, will be impacted.
Aluminum Sheets and Coils – These are widely used in various industries like automotive manufacturing and packaging.
Finished Metal Goods – Any other finished products that contain steel or aluminum, such as certain automotive parts, appliances, and machinery components, may also fall under the tariffs.
The proclamation also calls for enforcement against efforts to misclassify or evade the duties based on erroneous HTS codes.
Specifically, the Executive Order calls for CBP to prioritize reviews of the classification of imported steel articles and derivative steel articles and, in the event that it discovers misclassification resulting in non-payment of the ad valorem duties proclaimed, it shall assess monetary penalties in the maximum amount permitted by law and shall not consider any evidence of mitigating factors in its determination.
Additional information will be forthcoming once the implementing Federal Register notices and downstream products are identified. We will continue to monitor this matter and provide substantive updates. If you have questions concerning product coverage, please contact one of the trade professionals listed here.