Updates to Section 232 Tariffs on Steel and Aluminum

We would like to inform you about the upcoming changes to the Section 232 tariffs on steel and aluminum products, which will take effect on:
March 12, 2025.

On that date, all countries will be subject to a 25% tariff on steel and aluminum products, as well as specified derivative products, imported into the United States.

Overview of Changes

Tariff Reimposition

President Trump signed proclamations on February 10, 2025, reimposing tariffs on steel and aluminum articles. The tariffs for steel articles and derivative steel articles are set at 25%, while the tariffs for aluminum articles and derivative aluminum articles have increased from 10% to 25%.

Product Scope Expansion

Section 232 tariff are listed in Subchapter III of Chapter 99 of the Harmonized Tariff Schedule of the United States, all countries will be subject to a 25% tariff. It is anticipated that the list of steel and aluminum derivative products will cover much more than the current derivative list. This means that more items will now fall under the tariff regulations.

Documentation

It is essential to proactively advise purchasing on the documentation requirements (especially for items listed as U.S. origin). Necessary documentation include: Mill Certificates for steel and Certificates of Analysis for aluminum.

HTS Subheadings

The annexes to this recent proclamation have not yet been released. It is expected to cover much more is covered currently. We will promptly advise once the updated annex has been published. It is important to note that Section 232 HTS are listed in Subchapter III of Chapter 99 for the HTS. We are awaiting updates on any additional HTS codes.

Keep in Mind

• Aluminum products from Russia will face a 200% duty rate.
• Derivative US steel or aluminum products may be exempt if proper certification is provided.
• All previous steel and aluminum agreements with trading partners are canceled, effective March 12.
• No exclusions or exemptions will be issued effective February 11, and existing exclusions will remain valid until expiration or volume exhaustion.
• The Commerce Department will develop a process for adding additional products to the tariff list within 90 days.
• No duty drawback will be allowed on these tariffs.
• CBP will prioritize reviewing classification and issue penalties for misclassification to avoid tariffs.
• Products subject to tariffs admitted into foreign trade zones after March 12 must be admitted as "privileged foreign status."
  

CASAS is here for you during this time. If you need any guidance, we’re happy and able to assist.

Please contact us at compliance@casasintl.com.

Thank you!