President Trump Imposes Additional Tariffs on Steel and Aluminum

At a Glance

• President Trump has now set 25% tariffs on imports of steel and aluminum from all countries (except Russian-origin products, which continue to have their own duty rate and process), and include Canada and Mexico — the United States’ two largest trading partners for these commodities.
• These new actions abolish all quotas, tariff-rate quotas and the exclusion processes.

The breaking tariff news continues — this time with a focus on steel and aluminum imports. On Monday, February 10, 2025, President Trump issued an executive order expanding his 2018 Section 232 national security tariffs targeting steel and aluminum, along with derivatives of these products. Prior to the February 10 executive order, the 2018 tariffs were set at 10% for aluminum articles and a defined list of derivative aluminum products, and at 25% for steel articles and a defined list of derivative steel products. Since the original establishment of the tariffs, various exemptions including an importer-specific exclusion process, country-specific quota and tariff-rate quota deals, and a general exclusion process were established over time.

President Trump has now set 25% tariffs on imports of steel and aluminum from all countries, including Canada and Mexico — the United States’ two largest trading partners for these commodities. Further, this new action abolishes all quotas, tariff-rate quotas and the exclusion processes.

Tariffs on Steel

The executive order pertaining to steel, “Adjusting Imports of Steel Into the United States,” has been released, with annexes referenced therein containing additional details on the exact product scope still pending from the White House.

At this point, we can report the following:

• The provisions for quotas in lieu of tariffs for Argentina, Australia, Brazil, Canada, Mexico, Korea, the European Union, Japan, the United Kingdom and Ukraine are canceled as of March 12, 2025.
• The product scope of the tariffs will be expanded to cover additional “derivative steel articles,” effective March 12, 2025. The list of those articles will be in an appendix that has not yet been publicly released. Based on the preamble to the executive order, it appears that these articles will include fabricated structural steel and prestressed concrete strand. However, for any derivative steel article that is not in Chapter 73 of the Harmonized Tariff Schedule, the additional duty will apply only to the steel content of the derivative steel article.
• The additional duties on derivative steel articles would exclude steel articles that are processed in a third country from steel that was melted and poured in the United States.
• The Section 232 product exclusion process is terminated, effective immediately. As of the date of the proclamation (February 10, 2025), the secretary of Commerce cannot consider any product exclusion requests or renew any product exclusion requests currently in effect. Product exclusions already granted will remain in effect until their expiration date or until the excluded product volume is imported, whichever occurs first. The secretary of Commerce will terminate any General Approved Exclusions (GAEs) as of March 12, 2025.
• Within 90 days, the secretary of Commerce will establish a process for U.S. producers to ask that additional derivative steel articles be put on the list of products subject to duties. The secretary of Commerce will then have 60 days to decide whether to approve the request.
• There will be no drawback allowed against these duties (or the steel duties previously mentioned).
• With respect to foreign trade zones (FTZs), on-hand steel in inventory in FTZs that is not in domestic status — i.e., whether in Non-Privileged Foreign Status (NPF) or Privileged Foreign Status (PF) — prior to March 12 will have the tariffs applied when entered for consumption into the United States on or after March 12, 2025.

We are continuing to review the details of the executive order and will provide updates as soon as possible.

Tariffs on Aluminum

The executive order pertaining to aluminum, “Adjusting Imports of Aluminum Into the United States,” has been released by the White House.

In brief, aluminum articles and derivative aluminum articles will be subject to a 25% duty beginning March 12, 2025, irrespective of origin (except Russian-origin products, which continue to have their own duty rate and process).

We are now in the process of analyzing the details of the aluminum executive order. It appears that the annexes to the executive order are not yet available; those annexes should have additional details on the exact product scope, especially of the derivative articles.

At this point, we can report the following:

• The executive order is a modification of the original Section 232 duties on aluminum articles and derivative aluminum articles, NOT a new action. It will mean effectively a 25% tariff for all aluminum (not 25% + 10%).
• The product scope of the tariffs will be expanded to cover additional “derivative aluminum articles,” effective March 12, 2025. The list of those articles will be in an appendix that has not yet been publicly released. However, for any derivative aluminum article that is not in Chapter 76 of the Harmonized Tariff Schedule, the additional duty will apply only to the aluminum content of the derivative aluminum article.
• The additional duties on derivative aluminum articles would exclude aluminum articles that are processed in a third country from aluminum that was smelted and cast in the United States.
• The Section 232 product exclusion process is terminated, effective immediately. As of the date of the proclamation, February 10, 2025, the secretary of Commerce cannot consider any product exclusion requests or renew any product exclusion requests currently in effect. Product exclusions already granted will remain in effect until their expiration date or until the excluded product volume is imported, whichever occurs first. The secretary of Commerce will terminate any GAEs as of March 12, 2025.
• Within 90 days, the secretary of Commerce will establish a process for U.S. producers or industry associations to ask that additional derivative aluminum articles be put on the list of products subject to duties. The secretary of Commerce will then have 60 days to decide whether to approve the request.
• There will be no drawback allowed against these duties.
• All aluminum and derivative aluminum articles will have to be entered in PF Status into FTZs beginning March 12, 2025, unless they qualify for domestic status (this is in contrast to the steel EO).
• The order directs U.S. Customs and Border Protection to prioritize enforcement of these duties, including reviewing classifications and production processes for evasion.
• The provisions on Russian aluminum and derivative aluminum articles from aluminum smelted or cast in Russia remain the same (i.e., 200% duty).

We are continuing to review the details of the executive order and will provide updates as soon as possible.

For More Information