On February 18, 2025, the anticipated Annex to the original Executive Order (EO) was published in the Federal Register, providing details on the additional Harmonized Tariff Schedule (HTS) and scope for aluminum derivatives, steel and steel derivatives. The effective date of the increased tariffs is March 12, 2025.
Customs and Border Protection (CBP) published guidance on how the trade is to report and how the content of steel and aluminum found in derivatives is to be calculated. Importers will be required to certify and provide a separate valuefor the steel and aluminum content, as well as the steel and aluminum component weight in kilograms (kg). Customs Brokers will now be required to submit two entry lines, for each commercial invoice line that is eligible for this reporting. The full announcements may be found in the links provided. Aluminum Guidance / Steel Guidance
CBP provided an update on the application of section 232 quotas and how they must be processed prior to March 12, 2025. A summary is provided below, as well as, the full message here.
- All Section 232 tariff rate and absolute quotas shall expire on March 11, 2025.
- All Section 232 tariff rate and absolute quotas entries must be presented to CBP during officia office hours per 19 CFR 132.3, 8:30 a.m. to 4:30 p.m. local port time, on March 11, 2025.
- Entries that do not achieve quota status by 4:30 p.m. local port time on March 11, 2025, do not qualify for the Section 232 quotas and must be refiled as non-quota entries on March 12, 2025
CBP also distributed a chart and the current Steel and Aluminum HTS list impacted by the upcoming section 232 tariffs. The chart summarizes the duty rates, CH 99 HTS, and their effective dates.
Please see the below updated summary of changes announced.
- Effective Date: March 12, 2025
- Affected Countries: All countries
- Countries which will no longer receive exception from increased Section 232 tariffs: Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korea, the U.K., Ukraine, and the EU. The US Harmonized Tariff Schedule defined the following countries as included in the EU: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia (Czech Republic), Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.
- Tariff Increase: 25% – Section 232 duties will apply on steel and aluminum imports, thereby ending Section 232 exemptions and quota agreements for the above listed countries
- Turkey – (UPDATE) Steel & steel derivatives with country of origin Turkey will receive a 25% tariff to imports.
- Russia – Aluminum & aluminum derivatives with country of origin Russia will receive a 200% tariff to imports.
- Steel & Aluminum Derivative Products: Additional steel & aluminum derivative products will be subject to a 25% tariff, but only after the Commerce Department confirms “adequate systems” for revenue processing.
- Exemptions for Steel & Aluminum Derivatives: Steel & Aluminum derivatives processed from steel or aluminum melted and poured in the U.S. are exempt, provided importers supply CBP with data on steel or aluminum content.
- Adding Products: A process will be established for producers or trade associations to request additional steel & aluminum derivative products be added to the tariff list.
- End to Exclusions: The exclusion process for Section 232 steel & aluminum tariffs is ending; no new exclusions will be considered. Existing exclusions remain until they expire or the volume is imported, with all general exclusions ending on March 12.
- Complete List of Impacted Articles: Annex(s) published
- Enforcement: “CBP shall prioritize reviews of the classification of imported aluminum article and derivative aluminum articles and, in the event that it discovers misclassification resulting in loss of revenue of the ad valorem duties proclaimed herein, it shall assess monetary penalties in the maximum amount permitted by law…”
-Proclamation 10896-Adjusting Imports of Steel Into the United States, with Annex: HERE
-Proclamation 9980-Adjusting Imports of Derivative Aluminum Articles and Derivative Steel Articles Into the United States, with Annex: HERE
US Presidential Executive Order on Aluminum Imports may be found HERE.
US Presidential Executive Order on Steel, Steel Derivatives and Aluminum Derivatives may be found HERE.
US Presidential Factsheet on Section 232 Steel and Aluminum Increased Tariffs of 25% may be found HERE.
If you have any questions, please contact our Compliance Team or your JSC account supervisor.
