SECTION 232 STEEL AND ALUMINUM TARIFF EXPANSION
On February 10th, an executive order expanded the Section 232 tariffs on steel and aluminum, effective March 12th, 2025. This change will result the 25% tariff being applied to additional derivative products, and products which may have previously been excluded from the original list
- Tariff Application:
- For steel and aluminum derivative products outside of HTSUS Chapters 73 and 76, tariffs apply only to the steel or aluminum content.
- Aluminum products with Russian primary aluminum origin will face a 200% duty.
- Cancelled Agreements: All previous steel and aluminum trade agreements with key partners (Argentina, Australia, Brazil, Canada, EU, Japan, Mexico, S. Korea, Ukraine, UAE, UK) are cancelled as of March 12th.
- Existing Exclusions: Existing product specific exclusions are valid until their expiration or volume limit is reached.
- No New Exclusions: No new product or country-wide exclusions will be granted. Existing country-wide exclusions expire March 12th. Existing product specific exclusions remain until their expiration.
- No Duty Drawback: Duty drawback is prohibited on these tariffs.
Companies who bring in products containing steel and aluminum should reference the Federal Register Notices carefully to determine whether this change will impact their imports, and their bottom line. Steel and Aluminum products each have their own FRN and associated HTS codes. Importers should also reference the original FRN from 2020, in case they have a product which may have previously been exempt from the tariffs due to an exclusion which will now be expiring.
Additional reference:
Federal Register: Adjusting Imports of Steel Into the United States (2025)
Federal Register: Adjusting Imports of Aluminum Into the United States (2025)
RECIPROCAL TARIFFS
The Trump administration announced its intention to implement a "Fair and Reciprocal Plan" to establish tariffs that match those imposed by other countries on U.S. goods. This involves assessing not only tariffs but also other trade barriers, such as non-tariff measures.
Implementation and Timeline: Agency reports on trade issues are due April 1st, 2025. Following these reports, the Secretary of Commerce and the U.S. Trade Representative will take action to investigate and address non-reciprocal trade practices. Pending the results of this investigation, new tariffs, or other trade related barriers and measures, could be announced as early as April 2nd.
CANADA, MEXICO and CHINA TARIFF UPDATE
Earlier this week, President Donald Trump announced that the 25% tariffs on Canada and Mexico are on track to go into place on March 4th, following the scheduled 30 day pause, and that he would also impose an additional 10% tax on Chinese imports. The additional tariffs on China come on top of the previous 10% duty implemented earlier this month, when he delayed tariffs on Canada and Mexico. The 25% tariffs apply to all Canadian and Mexican imports, except for energy products from Canada, which will be taxed at 10%.
Please find earlier client tariff updates here: 02.03.2025: Client Advisory – New Tariffs Announced on February 1, Effective February 4