Section 232 Tariffs
Steel and Aluminum Update
February 18, 2025
On Friday, February 14th, the official annex lists (containing all the specific HTS codes) were made available for steel and aluminum. The full list of codes can be found below in links to the official Federal Register Memos.
As a reminder, this renders all previous aluminum and steel agreements with trading partners invalid, effective March 12th. No exclusions or exemptions will be issued. However, if you have a current exclusion, it will be effective until the expiration date or until the volume has been exhausted.
February 13, 2025
Starting March 12, 2025, a 25% tariff will apply to all steel and aluminum imports, including specified derivative products. Additionally, an expanded list of derivative products will also be subject to tariffs. However, these tariffs will only take effect once the Secretary of Commerce confirms that an efficient system is in place to process and collect duties. As soon as the updated Annex listing the expanded derivative products is available we will share an update.
Key Details:
- Steel Tariffs: If a derivative steel product listed in the Annex is not classified under Chapter 73 of the HTSUS, the 25% tariff will apply only to the steel content of that product.
- Aluminum Tariffs: If a derivative aluminum product listed in the Annex is not classified under Chapter 76 of the HTSUS, the 25% tariff will apply only to the aluminum content of that product.
- Russian Aluminum: Any aluminum product or derivative made from primary aluminum of Russian origin will face a 200% tariff. (Primary aluminum refers to newly produced aluminum extracted from alumina via the Hall-Heroult process.)
- Exemptions for U.S. Steel & Aluminum: If a derivative steel product is made from steel melted and poured in the U.S., and certification is provided to CBP, it will not be subject to additional tariffs—regardless of where it was processed. The same applies to aluminum derivative products if CBP is given the necessary documentation. Guidance on required documentation will be published soon.
Trade Agreements & Exclusions:
- All previous trade agreements covering steel and aluminum imports with Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, Ukraine, the UAE, and the UK will be terminated on March 12.
- Steel & Derivatives from Turkey: Imports will be subject to a 50% tariff.
- No More Exclusions: Effective February 11, 2025, no new exclusions or exemptions will be granted. Existing exclusions will remain valid only until their expiration date or until the approved volume is exhausted—whichever comes first.
Additional Changes:
- Adding More Products to the Tariff List: The Commerce Department has 90 days to establish a process for adding additional products to the Annex. U.S. steel and aluminum producers (or their industry associations) can petition to include more products, and Commerce will issue a decision within 60 days of a request.
- No Duty Drawback: These tariffs cannot be refunded through duty drawback claims.
- Strict Enforcement & Penalties:
- CBP will prioritize reviewing steel and aluminum classifications. If misclassification is found to avoid tariffs, penalties will be issued without mitigation.
- For aluminum misclassification, CBP will enforce maximum monetary penalties allowed by law.
- Foreign Trade Zones (FTZ): Any steel or aluminum product (or derivative) entering a foreign trade zone on or after 12:01 AM, March 12, 2025, must be admitted as "privileged foreign status" unless it qualifies for "domestic status"—meaning it will be subject to duties upon entry for consumption.
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