Section 232 Steel and Aluminum Tariffs (2025)

Section 232 of the Trade Expansion Act of 1962 authorizes the President to impose tariffs on imports that the Secretary of Commerce determines threaten to impair U.S. national security. Steel and aluminum have been subject to Section 232 tariffs since 2018. The Trump administration has significantly expanded and increased those tariffs in 2025, with the current rate standing at 50% on steel, aluminum, and a rapidly growing list of derivative products from nearly all trading partners.

The February 2025 Proclamations: Foundation of the 2025 Expansion

On February 10, 2025, President Trump signed two proclamations that restructured and expanded the Section 232 tariff framework, effectively replacing the 2018 orders and eliminating most of the country-based exemptions that had been in place:

Aluminum Imports Into U.S.; Adjustments (Proc. 10895) [TEXT] [PDF]
Steel Imports Into U.S.; Adjustments (Proc. 10896) [TEXT] [PDF]

These proclamations built on — and in significant respects amended and replaced — the 2018 Section 232 orders. The March 12, 2025 implementing regulations published by the Bureau of Industry and Security (BIS) provided the following key details:

Raised aluminum tariff from 10% to 25% (subsequently increased to 50% in June 2025 — see below)
Eliminated country-based exceptions and differences for steel imports — tariffs now apply uniformly to nearly all trading partners
Closed the exclusion portal — no new exclusion requests are being entertained
Revoked general exclusions previously in effect
Allowed specific product exclusions to expire without renewal
Created a domestic content exemption: tariffs do not apply if steel articles are made from steel “melted and poured” in the United States, or if aluminum articles are made from aluminum “smelted and cast” in the United States
Extended tariffs to steel and aluminum derivatives outside Chapters 73 and 76 of the HTSUS, with duties applied to the value of the steel or aluminum content of the article rather than the full value
Increased CBP enforcement and scrutiny of aluminum and steel imports, with an explicit attempt to eliminate mitigation of maximum assessed penalties for misclassification
Established a process for adding additional steel or aluminum derivatives to the tariff list upon request from a producer or industry association, subject to Commerce Department approval
Included empty aluminum cans and beer cans — by separate order

The BIS implementing regulations for the March 12, 2025 effective date are available here:

June 2025: Rate Increase to 50%

On June 3, 2025, President Trump signed Proclamation 10947, doubling the Section 232 tariff rate from 25% to 50%, effective June 4, 2025 at 12:01 a.m. EDT. The stated rationale was that the 25% rate had not sufficiently enabled the domestic steel and aluminum industries to reach the production capacity utilization levels necessary for sustained health and national defense needs.

Key details of the June 2025 rate increase:

50% rate applies to all covered steel, aluminum, and derivative products from nearly all trading partners, effective June 4, 2025
United Kingdom exception: UK-origin steel and aluminum products remain subject to 25% tariffs pursuant to the U.S.-UK Economic Prosperity Deal announced May 8, 2025. The Secretary of Commerce has authority to adjust this arrangement.
Chapter 73 and 76 derivatives: The June proclamation modified the duty basis for derivatives classified under Chapters 73 (steel articles) and 76 (aluminum articles) — these are now subject to Section 232 duties based solely on the value of their steel or aluminum content, consistent with how other derivatives are treated
Foreign Trade Zones: Steel and aluminum products admitted into a U.S. FTZ before June 4 in privileged foreign status are subject to the 50% rate upon entry for consumption, even if admitted at the lower 25% rate
Tariff stacking — Canada and Mexico: The June proclamation reversed the prior stacking order. Section 232 steel and aluminum tariffs now take precedence over IEEPA fentanyl-related tariffs on Canadian and Mexican goods. Canadian and Mexican steel and aluminum face the 50% Section 232 rate but are exempt from IEEPA tariffs on those same goods.
Derivative products and reciprocal tariffs: For derivative products, the 50% Section 232 rate applies to the steel or aluminum content value, and IEEPA reciprocal tariffs apply to the remaining non-steel, non-aluminum value of the product

August 2025: 400+ New Derivative Product Codes Added

In August 2025, the Commerce Department added more than 400 product categories to the list of steel and aluminum derivatives subject to Section 232 tariffs. The additions cover a wide range of manufactured goods including wind turbines and components, mobile cranes, bulldozers and heavy equipment, railcars, furniture, compressors, pumps, and hundreds of other product categories. The 50% tariff rate applies to the steel and aluminum content value of these newly added derivatives.

Commerce has established an annual inclusion process with three windows per year — in May, September, and January — through which producers and industry associations can request additional derivative products be added to the tariff list.

Key Compliance Points for Importers

The rapid expansion of Section 232 tariffs has created significant compliance complexity. The most important points for importers to understand:

No exclusions available. The exclusion portal is closed and no new exclusion requests are being entertained. Existing specific exclusions have expired and cannot be renewed. If your goods were previously covered by an exclusion, that coverage is gone.
Domestic content exemption. The one available avenue to avoid these tariffs is demonstrating that your steel was melted and poured in the United States, or your aluminum was smelted and cast in the United States. Documentation of the melt/pour or smelt/cast country is required at entry.
Derivatives require steel/aluminum content valuation. For derivative products outside Chapters 73 and 76 — and now including Chapter 73 and 76 products under the June proclamation — duties are calculated on the value of the steel or aluminum content only, not the full value of the article. Accurate content valuation is a compliance requirement.
No penalty mitigation for misclassification. The proclamations explicitly direct CBP to eliminate mitigation of maximum penalties for misclassification violations. Importers who misclassify goods to avoid Section 232 duties face maximum penalty exposure with no administrative relief.
Section 232 and IEEPA tariffs interact. Goods subject to Section 232 steel and aluminum tariffs are exempt from IEEPA reciprocal tariffs on the steel or aluminum content. However, derivative products are subject to IEEPA reciprocal tariffs on their non-steel, non-aluminum content value. The tariff stacking rules are complex and entry-specific.
Section 232 automotive tariffs take precedence. If a product is subject to Section 232 automotive tariffs, it is not subject to Section 232 steel and aluminum tariffs, IEEPA Canada, or IEEPA Mexico tariffs on the same goods.

Questions About Section 232 Compliance?

The 2025 expansion of Section 232 tariffs has left many importers with significant new duty exposure and complex classification questions. Great Lakes Customs Law advises importers on Section 232 compliance, derivative product classification, domestic content documentation, and duty protests for entries where Section 232 tariffs were incorrectly assessed. Call us at (734) 855-4999 or contact us online.

[lastupdate]