Hammer Set to Fall on Steel and Aluminum Imports

Presidential Proclamations Release Details on Expansive Tariffs on Items Containing Aluminum and Steel

On February 14, 2025, Presidential Proclamations 10895 and 10896 were published, delineating President Trump’s mandate for expanded 25% tariffs on imports of aluminum and steel respectively, and prescribing an additional 25% tax on the aluminum and steel components of a wide variety of industrial parts and commercial goods.

These new tariffs are instantiated in tariff legislation originally propounded by Trump in 2018 in under Section 232 of the Trade Expansion Act of 1962, but the new proclamations both expand and amend the 2018 legislation:

• Exemptions and quotas for aluminum and steel imports from Argentina, Australia, Brazil, Canada, EU countries, Japan, Mexico, South Korea, and the United Kingdom will be rescinded. Additionally, exemptions on steel from Ukraine has been rescinded as well. The exemptions for all of these countries will expire on 12:01 a.m. eastern time on March 12, 2025.
• The additional 10% tariff on aluminum imports from the 2018 legislation will be updated to 25%
• Therefore, all aluminum and steel imports as of March 12 will be taxed with an additional 25%
• “Aluminum Derivative Articles” and “Steel Derivative Articles,” that is, articles containing steel or aluminum components, will be subjected to the tariff, but only against the portion of the articles value represented by the aluminum/steel.
  Importers will be required to “provide to U.S. Customs and Border Patrol… any information necessary to identify the steel content used in the manufacture of [aluminum or steel] derivative article imports.” However, customs has not yet identified and implemented the specifics on what those requirements will be. The process must be established by the Secretary of Commerce by Thursday, May 15, 2025, and will not go into effect until the Secretary of Commerce has ensured “that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.”
• A process will be implemented by which domestic producers can petition to have additional HTS added to the list of aluminum and steel derivative articles subject to these tariffs
• The proclamations further specify that US customs should specially scrutinize the classification of aluminum and steel articles and aluminum and steel derivative articles, and assess applicable penalties against importers who have misclassified their imports to the maximum extent permitted by law

Key Takeaways:

The proclamations each contain an appendix of tariff codes subject to these new tariffs: Chapter 73 and 76 tariffs respectively for steel and aluminum articles, and then additional tariff codes that will be potentially subject to the 25% rate against the value of steel or aluminum components in the imported articles. These tariff codes affect commodities from multiple industries, including industrial machinery parts, electronic parts, and motor vehicle and aircraft parts; as well as commercial goods, such as umbrellas, lamps and light, furniture hardware, metal furniture, gym equipment, brooms. Allyn has compiled a full list of the subject HTS codes HERE.

These tariffs are specifically designed to discourage foreign imports and incentivize domestic sourcing of aluminum and steel by US businesses. In keeping with that intent, Importers wishing to mitigate the impact of these new tariffs will have few options, but may use the lead time before March 12, 2025 to review their supply chains for sourcing optimization. In the meantime, they should not expect any relief or reversal from these tariffs to be forthcoming given that the proclamations contain measures to further expand them. US business should also note the proclamations specifically direct US customs to scrutinize these imports and not consider mitigating factors in applying penalties. In other words, customs will be closely watching for both intentional and unintentional misinformation in US import declarations, and will apply severe punitive measures in either case.  Allyn International’s service suite includes consultation on current and developing issues in the US trade community. Reach Allyn here for a consultation or, contact us sales@allynintl.com or 239-489-9900.

Contributor: Andrew Dosher 

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About Allyn International 

Allyn International is dedicated to providing high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance.  Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North America, Europe, and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China and Prague, Czech Republic. For more information, visit www.allynintl.com.