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The Section 232 steel and aluminum 25% ad valorem tariffs are now in effect against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and derivatives from Russia are subject to 200% tariffs. Additionally, USCBP guidance again confirms that “melted and poured”/ “smelted and cast” reporting is due for all steel and aluminum articles and derivatives. All existing quotas and general/country exclusions have been terminated. These Section 232 tariffs are in addition to any other imposed duties or tariffs, including the recent IEEPA tariffs imposed against China, Mexico and Canada.
We anticipate retaliatory/counter-measures to be imposed by the European Union, Canada and other steel and aluminum producing countries. However, Australia has indicated that it will not impose retaliatory measures and Mexico may delay such measures and/or limit such measures only to similar steel and aluminum products. Ongoing monitoring will be provided.
As a follow-up to my earlier message, USCBP has now issued updated guidance (CSMS) regarding these Section 232 steel and aluminum tariffs confirming our earlier notice that the Secretary of Commerce had issued the certification indicating US-CBP is ready to collect Section 232 duties on the new steel and aluminum articles and the derivatives listed in Annex 1. (2025-04210.pdf)
The Updated USCBP guidance (CSMS) can be found here:
CSMS # 64384496 - UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products
CSMS # 64384423 - UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
CSMS # 64375535 - Quota Guidance: Proclamation 10896 of February 10, 2025, Adjusting Imports of Steel and Aluminum into the United States
Dan Ujczo | Senior Counsel | Thompson Hine LLP
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Dan.Ujczo@ThompsonHine.com
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