Back on February 11, President Trump imposed a 25% tariff on steel and aluminum articles and derivatives. As of June 4, he has increased the same tariff to 50%.
The details are in the proclamation Adjusting Imports of Aluminum and Steel into the United States. After the proclamation was issued, CBP issued three CSMS notices providing further detail, including applicable HTSUS provisions:
- CSMS #65236574 — Updated guidance on the proclamation and amendments to Executive Order 14289, including the revised tariff stacking priority order
- CSMS #65236645 — Updated guidance on import duties on aluminum and aluminum derivative products
- CSMS #65236374 — Updated guidance on import duties on steel and steel derivative products
What Changed on June 4
The headline change is straightforward: Section 232 tariffs on steel and aluminum articles and derivatives increase from 25% to 50% ad valorem for imports from all countries, with one exception. The United Kingdom retains the 25% rate, at least through the period contemplated by the U.S.-U.K. Economic Prosperity Deal — though the Commerce Secretary retains authority to impose quotas or increase duties if the U.K. fails to meet its commitments. Russia-origin aluminum and derivatives remain subject to the pre-existing 200% tariff, unaffected by the new proclamation.
The Non-Metal Content Change: A Significant New Complexity
The more operationally significant change — and the one that will require attention from importers who may not have been closely tracking these tariffs — is how the 50% rate now interacts with the non-steel and non-aluminum content of derivative articles.
Under the prior framework, articles subject to Section 232 duties were generally excluded from reciprocal tariffs. The June 3 proclamation changes that. It now specifies that “the non-aluminum, non-steel content of all aluminum and steel articles and derivative articles” is subject to Reciprocal Tariffs. In practical terms, this means derivative products will in many cases need to be reported on two separate entry summary lines: one line for the metal content, subject to the 50% Section 232 duty, and a second line for the non-metal content, subject to the applicable reciprocal tariff rate.
For products classified in HTS Chapters 73 (steel) and 76 (aluminum), the 50% Section 232 tariff now applies to the value of the metal content rather than the full entered value of the article — a change from the prior rule that applied the duty to the entire value of Chapter 73 and 76 goods. Where the value of the steel or aluminum content equals the total entered value of the article, the full value remains subject to the Section 232 rate. Where it is less, the reporting split is required.
Revised Tariff Stacking Order
The proclamation and the accompanying CSMS guidance also establish a revised priority order for applying multiple tariffs under Executive Order 14289. CBP’s instructions set out the following hierarchy:
- First: Determine whether the article is subject to the Section 232 Auto/Auto Parts tariff. If so, the article is not subject to Section 232 Aluminum, Section 232 Steel, IEEPA Canada, or IEEPA Mexico tariffs. USMCA-qualifying parts of passenger vehicles and light trucks are not subject to Section 232 Auto/Auto Parts, IEEPA Canada, or IEEPA Mexico tariffs.
- Second: If the article is not subject to Section 232 Auto/Auto Parts, determine whether it is subject to Section 232 Aluminum and/or Section 232 Steel tariffs. Articles subject to Section 232 are excluded from IEEPA Canada and IEEPA Mexico tariffs. Derivative products subject to both aluminum and steel tariffs owe duties on the value of each applicable metal content separately.
- Third: For the non-metal content of derivative articles, determine the applicable reciprocal tariff.
Reporting and Documentation Requirements
CBP’s CSMS guidance sets out specific reporting requirements that importers and brokers need to follow for entries filed on or after June 4, 2025:
- Country of melt and pour must be reported for steel and steel derivative articles using ISO country codes.
- Country of smelt and cast — both primary and secondary — must be reported for aluminum and aluminum derivative articles. If the country of smelt or cast is unknown, importers should report “unknown,” but be aware that CBP will assess the 200% Russia-rate Section 232 duties on that line.
- Correct Chapter 99 HTS codes must be used for each applicable tariff action. CBP has stated it will strictly enforce compliance, including through fines and loss of import rights for violations.
- FTZ admissions on or after June 4, 2025 must be made under “privileged foreign status,” and the merchandise will be subject to the new 50% rates upon entry for consumption.
- Supporting documentation establishing metal content values and country of origin of the metal must be maintained in the importer’s records.
Uncertainties Remain
There are still open questions in the implementation. The scope of which derivative articles are captured, how content values are to be determined in complex multi-material articles, and how CBP will handle entries where the metal content cannot be readily isolated are among the issues the trade community is working through. Additional CSMS guidance and Commerce Department notices can be expected as CBP and the administration clarify the framework. Importers with affected supply chains should not wait for that clarity before reviewing their classification and reporting practices.
Steel and Aluminum Tariff Questions?
Do you have questions about the Section 232 steel and aluminum tariff increase and how it affects your imports? Great Lakes Customs Law has been advising importers for more than 15 years on tariff classification, compliance, and duty exposure. Call us at (734) 855-4999, send a text message, or reach us on WhatsApp.
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