As of June 4, 2025, aluminum and steel and their derivative products will face a 50% Section 232 tariff. The only exception is aluminum and steel from the United Kingdom (UK), which will remain at 25%. For the full Executive Order (EO), see https://www.whitehouse.gov/presidential-actions/2025/06/adjusting-imports-of-aluminum-and-steel-into-the-united-states/
a. Duties Based on Steel/Aluminum Content
The 50% tariff rate applies only to the aluminum and steel content. The remaining portion of the product's value will be subject to reciprocal tariffs (IEEPA II). As a result, the entire value of the product is subject to some sort of tariff.
In addition, for derivative products subject to both Section 232 aluminum and steel tariffs, duties will be owed on both the value of the aluminum and steel content of that product.
In the case where the value of the aluminum and steel content is less than the entered value of the imported article, importers will need to report a non-aluminum/steel content line, subject to reciprocal tariffs, and an aluminum/steel content line, subject to Section 232 tariffs. Specific instructions include:
Non-aluminum/steel content, first line:
- Chapter 1-97 HTS, this same HTS must be reported on both lines
- Country of origin, same must be reported on both lines
- Total entered value of the article less the value of the aluminum/steel content
- Report the total quantity of the imported goods
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties
Aluminum/steel content, second line:
- Same Chapter 1-97 HTS reported on the first line
- Same country of origin reported on the first line
- Report 0 for quantity for the Chapter 1-97 HTS
- Report the value of the aluminum/steel content
- Report the Section 232 duties based on the value of the aluminum/steel content with the Chapter 99 HTS
- Report a second quantity (of the aluminum/steel content) in kilograms with the Chapter 99 HTS
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties
b. Steel/Aluminum from Canada or Mexico
For aluminum and steel imports from Canada or Mexico, the EO reverses the previous tariff stacking order announced on April 29, 2025.1 The following order now applies:
- If Section 232 auto/auto parts tariff applies, then the article
is NOT subject to Section 232 aluminum, Section 232 steel, IEEPA I
(fentanyl) Canada, or IEEPA I (fentanyl) Mexico tariffs
- NOTE: USMCA-qualified automobiles and automobile parts are not subject to the Section 232 auto/auto parts, IEEPA I Canada, or IEEPA I Mexico tariffs
- If Section 232 aluminum and/or steel tariffs apply, then the article is NOT subject to IEEPA I (fentanyl) Canada, or IEEPA I (fentanyl) Mexico tariffs
c. Foreign Trade Zones
The EO applies retroactively for covered products admitted into a U.S. foreign trade zone (FTZ) under "privileged foreign status." This means any aluminum and steel product admitted into a U.S. FTZ prior to June 4, 2025, will be subject to the 50% tariff rate upon entry.
d. Exclusions and Drawback
Product-specific exclusions for Section 232 duties will remain in effect until their expiration date or until the excluded product volume is imported, whichever comes first. Additionally, no duty drawback is available.
e. Refunds
Since the EO applies retroactively, importers may request a refund for duties no longer due. However, importers may not request refunds for IEEPA I (fentanyl) tariffs paid on products from Canada or Mexico because the EO does not apply retroactively to the new stacking order.
Requests for refunds were available on May 16, 2025, by filing a post summary correction (PSC) for unliquidated entries or filing a protest for entries that have liquidated but where the protest period has not expired.
f. Strict Enforcement
The EO orders U.S. Customs and Border Protection (CBP) to mandate strict compliance with declaration requirements for aluminum and steel content in imported products. Additionally, the EO orders CBP to outline maximum penalties for noncompliance, including but not limited to significant monetary penalties, loss of import privileges, and criminal liability.
Footnote
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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.
