This article was originally published on February 11, 2025. It has been updated to reflect changes from additional Presidential Actions. An additional Presidential Proclamation was published on the evening of February 11, 2025.
The White House issued a Fact Sheet and Presidential Proclamation addressing Section 232 tariff actions on February 10, 2025. These steps strengthen President Trump's 2018 tariff actions on steel and aluminum imported into the United States. Only the Presidential Proclamation on steel imports was available to the public as of February 11.
What is Changing for Steel Imports – The Presidential Proclamation results in a 25% ad valorem tariff on all steel and aluminum imports in addition to any other duties that may apply. Changes to the existing Section 232 program include eliminating alternative agreements, exemptions, and exclusions that previously limited application of the duties. The President also seeks more stringent "melted and poured" standards, expanded scope to certain downstream products, and efforts to target duty evasion through tariff misclassification. The drawback will not be available for duties imposed under the Presidential Proclamation.
What is Changing for CBP Enforcement – The Presidential Proclamation signals an appreciable change in the enforcement posture by U.S. Customs and Border Protection ("CBP"). Going forward, if CBP finds misclassification of steel articles, it will pursue maximum civil penalties without considering evidence of mitigation.
When are Changes Effective for Steel Imports – March 12, 2025, is the effective date for removing special arrangements with foreign countries, generally approved exclusions, and for the imposition of tariffs on additional derivative steel articles. Countries of origin impacted by this change include Argentina, Australia, Brazil, Canada, EU countries, Mexico, South Korea, the United Kingdom, and Ukraine. A list of additional derivative steel articles impacted by this change will appear in a forthcoming Annex I to be published in the Federal Register. Dates are subject to the announcement that adequate systems are in place to process and collect tariff revenues. Also, no new product exclusions will be available following February 10, 2025. Any currently granted product exclusions will remain effective until the latter of their expiration date or until the excluded product volume is imported.
Why the Change is Occurring – The rationale for these actions under the Trade Expansion Act of 1962 is to protect national security interests in domestic steel and aluminum production from unfair trade practices.
How Supply Chains Can Prepare – United States importers and industries reliant on imported goods are entering a higher-cost operating environment. Strong procurement, operational, and sales planning is key for managing the impact of steel imports and all other recent tariff actions. Those proactive steps often involve confirming HTS codes and country of origin, examining necessary volumes for immediate and long-term demand, considering the availability of alternate supply from domestic sources, and revisiting buy-side and sell-side contract terms. Finally, companies with symbolic significance for the United States (such as Kentucky bourbon) will need to stay alert to possible retaliatory tariffs on exports to our trading partners.
Additional client bulletins on effective supply chain strategies are available here:
Trump Tariffs – 2025 Expectations, Facts, and Options
UPDATE: Trump Tariffs on Mexico, Canada, China – Supply Chain Impact and Strategies
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
