IEEPA Tariffs, Steel & Aluminum, Current Section 232 & 301 Investigations

 

As of March 4, 2025, effective dates and amounts became clear relating to Canada, Mexico and China. However, with the announcement of Canada & Mexico effective yesterday at 25% and China at an additional 10% (total 20%) under IEEPA, all have announced imposed retaliatory tariffs. President Trump has indicated any retaliatory tariffs will cause our tariffs to that country to increase by the same amount. In his speech last night, he indicated that any retaliatory tariffs against countries retaliating against us will be effective April 2, 2025. 


The below is our understanding based on information available as of this message.


IEEPA is the vehicle by which these tariffs are being imposed which is different from the USTR SEC 232 and 301 tariff actions. However, IEEPA tariffs are in addition to any SEC 232 or 301 duties as well as any regular duty on your commodities.


CHINA:


President Trump issued an Executive Order (EO) on February 1, 2025 imposing 10% additional duty on Chinese products as of February 4, 2025. An exception was made for goods loaded onto a vessel or in transit on the final mode of transport prior to entry into the US by 1/31/25 provided they arrive no later than 3/7/25. Any shipment which did not qualify for this exception was immediately subject to the 10% additional duty. Any shipments arriving after 3/7/25 were to also be subject to the additional 10% duty. On March 3, 2025 a new EO was issued changing the 10% tariff imposed to a 20% tariff effective March 4, 2025.


CANADA:   


President Trump issued an Executive Order (EO) on February 1, 2025, imposing an additional 25% duty on Canadian products as of February 4, 2025 with an exception for goods loaded onto a vessel or in transit via final mode of transport by January 31, 2025. That same day, President Trump postponed for 30 days this additional duty after reaching an agreement with Canada’s Prime Minister. On March 2, 2025, it was announced the additional tariff of 25% will be effective March 4, 2025, with the exception being energy products which will be 10% additional duty.


MEXICO:


President Trump issued an Executive Order (EO) on February 1, 2025, imposing an additional 25% duty on Mexican products as of February 4, 2025. That same day, President Trump postponed this additional duty for 30 days after reaching an agreement with Mexico’s President. On March 2, 2025, it was announced the additional tariff of 25% will be effective March 4, 2025.


STEEL & ALUMINUM ARTICLES:


STEEL:


A Presidential Proclamation was issued February 10, 2025 imposing 25% on all imports of steel products and derivatives. It revoked all agreements that suspended Section 232 tariffs, except for granted exclusions which were applied for through the Section 232 exclusions portal. Granted exclusions will remain in effect until either the expiration of the exclusion or the quantity excluded is filled, whichever comes first. The effective date for these revocations is March 12, 2025. Steel articles and derivatives previously subject to Section 232 will remain subject to the 25% tariffs. Newly announced steel derivatives which now include downstream derivatives (Annex I) classified in CH. 73 will go into effect March 12, 2025. Steel derivatives in the revised Proclamation but not in CH 73 will not take effect until notification is received by the Commerce Secretary that a system is in place to collect additional duty. This additional duty will only apply to the declared value of the steel content in the derivative article to report in kilograms.


ALUMINUM:


A Presidential Proclamation was issued increasing the tariff from 10% to 25% for all imports of aluminum products and derivatives. It revoked all agreements that suspended Section 232 tariffs, except for granted exclusions which were applied for through the Section 232 exclusions portal. Granted exclusions will remain in effect until either the expiration of the exclusion or the quantity excluded is filled, whichever comes first. The effective date for these revocations is March 12, 2025. Aluminum articles and derivatives previously subject to Section 232 will remain subject to the 25% tariffs. Newly announced aluminum derivatives which now include downstream derivatives classified in CH. 76 will go into effect March 12, 2025. Aluminum derivatives not in the revised Proclamation and not in CH 76 will not take effect until notification is received by the Commerce Secretary that a system is in place to collect additional duty. This additional duty will only apply to the declared value of the aluminum content in the derivative article to report in kilograms.


SECTION 232 CURRENT INVESTIGATIONS:


COPPER: President Trump has issued an Executive Order (EO) directing the Commerce Secretary to investigate copper imports into the United States and their threat to national security and economic stability. The White House also released a fact sheet on this matter.


LUMBER & TIMBER: President Trump has issued an Executive Order (EO) directing the Commerce Secretary to investigate imports of timber, lumber, and their derivatives into the United States. The White House also released a fact sheet on this matter.


SECTION 301 CURRENT INVESTIGATIONS:


DIGITAL SERVICE TAXES (DST): President Trump has issued a memorandum directing multiple government agencies to investigate the impact to the United States of DST charged to US companies by other countries. The White House also released a fact sheet on the matter.


CHINA MARITIME, LOGISTICS & SHIPBUILDING SECTOR: The US Trade Representative (USTR) issued notice of an investigation into China for these sectors on April 17, 2024. On January 23, 2024, USTR announced they determined these practices could be actionable under Section 301. On February 27, 2025, the USTR issued their request for comments and notice of public hearing on their proposed action, including service fees to Chinese Maritime Transport Operators. You are urged to review this as the proposed service fees would undoubtedly be passed down by the carriers to the cargo owners. Instructions to submit your own comments are in Sections IV & V.


The European Union has been mentioned as being on the horizon with 25% imposed, but we've yet to receive any official confirmation of rate or effective date.


We understand the impact this is having on both you and your customers and will do our best to provide you with information upon confirmation via official US Government channels. Often these postings are a day or two after being announced, so we wait in case there are any changes.


Should you have any questions, we will do try to answer them to the best of our ability.


Thank you for your continued partnership with WEST Forwarding Services.


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