| On Thursday, April 2, President Trump signed a new proclamation adjusting Section 232 tariffs for steel, aluminum, and copper, alongside a proclamation establishing new tariffs on pharmaceutical imports.
Below is a summary of these changes and their effective dates.
1. Steel, Aluminum & Copper: Adjusted Section 232 Tariffs
Effective 12:01 a.m. ET on April 6, new rules for calculating tariffs on steel, aluminum, and copper will take effect.
- 50% Tariff: Applies to articles made entirely (or almost entirely) of aluminum, steel, or copper (e.g., steel coils, aluminum sheets).
- 25% Tariff: Applies to “derivative articles” substantially made of these metals.
- 15% Tariff: Applies to certain metal-intensive industrial and electrical grid equipment (through 2027).
- 10% Tariff: Applies to products made abroad using 100% American steel, aluminum, and copper.
- Exempt: Products containing 15% or less steel, aluminum, or copper are no longer subject to these Section 232 tariffs.
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2. Pharmaceuticals: New Import Tariffs
A new 100% tariff has been imposed on patented pharmaceutical products and ingredients. The timeline for implementation is:
- Large Companies: Effective in 120 days.
- Smaller Companies: Effective in 180 days.
Key Exceptions and Reductions:
- 15% Tariff: Applies to products from the EU, Japan, Korea, Switzerland, and Liechtenstein.
- Lower Negotiated Rate: Applies to products from the United Kingdom, subject to the UK pharmaceutical agreement.
- 0% Tariff: Available through January 20, 2029, for companies that enter into both Most Favored Nation (MFN) pricing agreements with Health and Human Services and onshoring agreements with the Commerce Department.
- 20% Tariff: Applies to companies that enter into onshoring agreements only.
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Compliance and Enforcement
The administration has emphasized that these measures include strong monitoring and enforcement mechanisms. This includes the possibility of external audits and retroactive tariff increases on past imports for non-compliance.
Currently, the trade community is pending final guidance from CBP on the implementation. JSC Compliance will continue to monitor and distribute updates when they become available. If you have any questions, please contact our JSC Compliance team. |
