The Trump Administration announced, through presidential proclamations on February 10 and 11, 2025, previously discussed here, that the United States would impose 25% tariffs on all steel, aluminum and their derivative products.
The US Department of Commerce published in the Federal Register, for steel, aluminum and their respective derivative products, the full list of products on which the tariffs would be imposed effective March 12 along with corresponding changes to the Harmonized Tariff Schedule of the United States.
The US Customs and Border Protection also issued guidance on the implementation of the tariffs on steel, aluminum and their respective derivative products setting out, among others, the reporting requirements on the products caught by the tariffs.
Canadian Retaliatory Tariffs
Finance Minister Dominic LeBlanc has announced that the Government of Canada, following a dollar-for-dollar approach, will be imposing, as of 12:01 am Thursday, March 13, a 25% reciprocal tariff on C$29.8 billion worth of US goods. Products impacted include steel products worth C$12.6 billion and aluminum products worth C$3 billion as well as additional imported US goods worth C$14.2 billion for a total of $29.8 billion. Examples of additional products include computers, sports equipment, and cast-iron products. The Department of Finance published the full list of products here.
Pursuant to the announcement, the Government of Canada published the Customs Notice 25-11: United States Surtax Order (Steel and Aluminum 2025) and the United States Surtax Order (Steel and Aluminum 2025), bringing into force on March 13, the 25% surtax on certain steel, aluminum and their derivative goods eligible to be marked as being from the US under the US-Mexico-Canada Agreement1 (CUSMA or USMCA). Canada's duty drawback and duties relief programs are available for any surtax paid or payable, subject to provisions of CUSMA.
These measures would be in addition to the existing first round of 25% retaliatory tariffs on imports worth $30 billion from the United States, discussed here. This new Department of Finance list, effective March 13, includes products that were listed in the Department of Finance's Notice of Intent discussed here regarding the second round of tariffs impacting $125 billion of imports from the US (21-day public consultation period expiring March 25, 2025).
EU Retaliatory Tariffs
On March 11, the European Commission also announced countermeasures on US goods worth up to €26 billion. Specifically, the EU:
- Re-imposed countermeasures on US goods which were slated to expire on March 31, 2025. These countermeasures were originally introduced in response to tariffs imposed by the Trump Administration in their first term in 2018 on EU steel and aluminum products; and
- Announced the intention to introduce new countermeasures effective mid-April 2025 on US goods following consultations with EU member states and stakeholders. The EU has published a notice on the consultation, which shall be held from March 12 to March 26, 2025.
Footnote
1. Specifically, under the Determination of Country of Original for the Purpose of Marking Goods (CUSMA Countries) Regulations.
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