In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.
TC Trade Alerts will serve as a central resource for identifying the policy changes, executive orders, and necessary information and context regarding government actions affecting international trade.
See below for more information on the last TC Trade Alerts. If you have any questions about how this affects your business, please don't hesitate to contact one of our attorneys.
Additional Resources
Trade Compliance Handbook | Checklists of Foreign Countries Subject to Sanctions | Our International Trade Practice
| THOMPSON COBURN TRADE ALERT – IMPORTS | |
| HEADLINE | Department of Commerce Posts Certification of Systems Processing for Steel and Aluminum Tariffs; CBP Posts Implementation of Duties Beginning March 12, 2025 |
| DATE | 11 March 2025 |
| AGENCY | Bureau of Industry and Security, Department of Commerce; U.S. Customs and Border Protection |
| EFFECTIVE DATE | 12 March 2025 at 12:01 a.m. |
| BACKGROUND | President Trump signed Proclamations on February 10 removing
country-based and product-based exclusions for steel and aluminum, terminating the exclusion process,
increasing the duties on aluminum from 10% to 25%, and subjecting
additional derivative steel or aluminum articles to the additional
duties, as defined in Annex 1. The Proclamations required the Secretary of Commerce to certify that adequate systems are in place to process and collect tariff revenue for all covered articles. |
| DETAILS | The March 11 Notice certifies that adequate systems are now in
place to process and collect tariff revenue for covered articles
for both steel and aluminum. Shortly after, CBP issued CSMS Messages # 64384496 and # 64384423, announcing collection of 25% duties on stated steel and aluminum and derivative articles beginning March 12, 2025. The HTS classifications mirror those in the Federal Register notices for steel and aluminum. We note that for steel derivatives listed in 9903.81.91 and aluminum articles under 9903.85.08 for which the duty only applies to the steel content will need to be entered on 2 lines (line 1 as non-steel/aluminum content; line 2 as value of the steel/aluminum content). Importers must be able to provide information that may be requested by CBP to prove the content of aluminum or steel in the imported items. If the value of the steel or aluminum is unknown or is the same as the entered value, the duties will be based on the entire value of the derivative steel or aluminum article. Additionally, importers must report the melt and pour country of the steel and the smelt and cast country of the aluminum. |
| BASIS | Proclamations of 10 February, Section 232 of the Trade Expansion Act of 1962; 3 U.S.C. 301; 19 U.S.C. 2483 |
| HTS/PRODUCTS | Summary Chart: Section 232 chart Final
(1).pdf The aluminum and derivative aluminum products subject to the additional tariffs in Proclamation 9704 and Proclamation 9980. The steel and derivative steel products subject to the additional tariffs in Proclamation 9705 and Proclamation 9980. Steel List Aluminum List A fully searchable spreadsheet based on the Public Inspection Annexes is available here. |
| CITE | Unpublished Notice – Scheduled to be published March 14 CSMS # 64384423 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products CSMS # 64384496 – UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products |
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.
