On February 11, 2025, the Trump Administration published two Presidential Proclamations adjusting tariffs on steel and aluminum products. As of March 12, 2025, all countries will be subject to 25% tariffs on steel and aluminum products and specified derivative products imported into the United States.
Existing steel agreements with trading partners (including Argentina, Australia, Brazil, Canada, EU countries, Japan, Mexico, South Korea, and the United Kingdom) and aluminum agreements with trading partners (including Argentina, Australia, Canada, Mexico, EU countries, and the United Kingdom) are canceled effective March 12. Steel products from Turkey will be subject to a 50% tariff. Additionally, all aluminum articles or derivative aluminum articles made from aluminum smelted or cast in Russia will be subject to a 200% tariff.
Derivative steel and aluminum articles admitted into a U.S. Foreign Trade Zone (FTZ) after March 12, 2025, must be admitted as “privileged foreign status” and will be subject to the 25% tariff. Importers cannot reclaim these duties under the duty drawback program.
Exclusions
As of February 11, no new exclusions or exemptions will be issued. If an importer has an existing product-specific, importer-specific product exclusion for steel or aluminum products, the exclusion will remain effective until the expiration date or until their excluded volume is exhausted, whichever occurs first. The current general approved exclusions will lapse on March 12, 2025 and will not be renewed.
The proclamation establishes an exclusion for derivative steel products processed in another country if they originate from steel articles that were melted and poured in the U.S. and for derivative aluminum products processed in another country if they originate from aluminum articles that were smelted and cast in the U.S.
Authority & Rationale
Section 232 of the Trade Expansion Act of 1962 allows the president to impose import restrictions based on an investigation and affirmative determination by the U.S. Department of Commerce that certain imports threaten to impair U.S. national security. Commerce conducted investigations and released a report in February 2018 finding that excessive steel and aluminum imports had weakened the domestic industries, reducing their ability to meet national defense and critical infrastructure needs.
In response to this report, the first Trump Administration imposed a 10% tariff on aluminum and 25% tariff on steel imports in March 2018. The proclamation states that despite this action, aluminum imports into the United States have continued at unacceptable levels. As a result, domestic producers have been forced to idle additional production and shut down facilities. The proclamation states that this action is necessary to allow U.S. aluminum producers to restart production and to incentivize new capacity.
Next Steps
The proclamation directs several departments and agencies to take action to implement the policy:
- Within 90 days, Commerce must establish a process allowing U.S. steel and aluminum producers to request the inclusion of additional derivative products under these tariffs.
- Within 10 days, the United States International Trade Commission shall revise the HTSUS to reflect the new policy.
- The Secretary shall take all actions, including publication in the Federal Register, necessary to terminate the product exclusion process.
- CBP is directed to publish regulations or guidance implementing the requirements as soon as practicable.
- CBP is directed to promptly notify Commerce if it finds evidence of any efforts to evade payment of the additional duties.
- The Secretary may issue regulations and guidance to address operational necessity.
In addition, going forward, importers must provide steel and aluminum content information for derivative steel articles to U.S. Customs. CBP will prioritize the review of product classification for imported steel and aluminum articles. If misclassification is detected, maximum penalties will be imposed, with no consideration for mitigating factors.
Diaz Trade Law will continue to monitor for developments and will provide additional information as it becomes available.
Learn more:
