What we are tracking
- Presidential proclamation, Adjusting Imports of Steel into the United States – The White House, Feb. 10, 2025
- Presidential proclamation, Adjusting Imports of Aluminum into the United States – The White House, Feb. 11, 2025
These proclamations institute Section 232 tariffs (under the Trade Expansion Act of 1962) of 25% ad valorem on steel and aluminum at 12:01 a.m. ET March 12, 2025, for goods entered into the U.S. for consumption or withdrawn from warehouse for consumption. As an ad valoreum tariff, the 25% will be added to any existing tariff your company may incur.
Why it’s important
These tariffs are inclusive across all countries. In addition, to address foreign-produced steel and aluminum entering the U.S. through third countries, these proclamations also address “derivative products” or finished goods with the same tariff.
How it impacts you
Through various provisions, these tariffs supersede existing Section 232 tariff exceptions or exemptions under which your company may be operating to apply a 25% ad valoreum tariff on your company’s imported steel and aluminum products. In addition, duty drawback provisions are eliminated, which impacts the cost structure of intra-company transactions.
What to expect next
Current exclusions with time or quantity durations will expire with no new exclusion process. As such, companies must monitor their purchase and sales contracts and negotiations closely to capture the roll-off of 2018-era relief and these new ad valorem tariffs. Customs and Border Protection (CBP) documentation must be updated to ensure the correct tariffs are included on bills of lading and electronic data interchange systems. The specification of some information is yet to be decided by CBP.
Companies should increase their vigilance regarding bills of material and HTS codes, as there are also provisions directed at greater enforcement penalties for non-payment of tariffs. Monitoring is important as more derivative products may be added to these Section 232 tariffs.
