Tag: steel

New HTS Codes Subject to 50% Section 232 Steel and Aluminum duties

Posted by Jason P. Wapiennik on

As of August 18, the Bureau of Industry and Security (BIS) has added 407 HTS codes to the list of derivatives subject to steel or aluminum tariffs.

The notice, published this morning, is Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process. There is no in-transit exemption.

CBP issued CSMS # 65936570 – GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products

Steel and Aluminum Tariff Questions?

Do you have questions about the new steel and aluminum tariffs? We have answers for you. Great Lakes Customs Law has been advising importers for more than 15 years. Call us at (734) 855-4999 or fill out the form below:

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Last updated: August 19, 2025 at 19:31 pm

Section 232 Steel and Aluminum Tariffs Increase to 50%

Posted by Jason P. Wapiennik on

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 CSMS # 65236574, CSMS # 65236645, and CSMS # 65236374 providing further detail, including applicable HTSUS provisions.

There are still some uncertainties based on the text. However, a clear and significant change is that it additional tariffs will apply on the non-steel/non-aluminum portion of goods subject to section 232 duties, by stating that “the non-aluminum, non-steel content of all aluminum and steel articles and derivative articles” are now subject to Reciprocal Tariffs.

Steel and Aluminum Tariff Questions?

Do you have questions about the steel and aluminum tariffs? We have answers for you. Great Lakes Customs Law has been advising importers for more than 15 years. Call us at (734) 855-4999 or fill out the form below:

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Last updated: June 5, 2025 at 11:50 am

Trump Eases Stacking of Some Tariffs (Cumulative Effect)

Posted by Jason P. Wapiennik on

President Trump has issued a new Executive Order modifying the treatment of certain tariff measures. The purpose is to “avoid the cumulative effect of overlapping tariffs on certain articles” and provides the procedure for determining what tariffs apply. This has been called tariff “stacking” by many people.

This new action seems designed to benefit the automotive industry, and provide some measure of relief to Mexico and Canada. The Executive Order is called “Addressing Certain Tariff on Imported Articles” and is dated April 29, 2025 [text from whitehouse.gov].

In simplified form (perhaps lacking necessary legal nuances, so consult for legal advice), the Executive Order lists out the only 5 tariff measures affected, as follows:

(a)  Automobile & Automobile Part Tariffs – Adjusting Imports of Automobiles and Automobile Parts Into the United States
(b)  Canada Tariffs — Imposing Duties To Address the Flow of Illicit Drugs Across Our Northern Border),
(c)  Mexico Tariffs – Imposing Duties To Address the Situation at Our Southern Border
(d)  Aluminum Tariffs – Adjusting Imports of Aluminum Into the United States
(e)  Steel Tariffs – Adjusting Imports of Steel Into the United States

To determine whether tariffs should not be stacked or cumulated, the order, in our own summary, gives the following statements:

  • If tariffs under (a) apply, those goods will not be subject to (b) through (e) tariffs. (No steel, aluminum, Canada or Mexico tariffs on automobile or automobile part tariffs).
  • If tariffs under (b) or (c) apply, then those goods will not be subject to (d) and (e) tariffs. (If either Canada or Mexico tariffs apply, then no steel or aluminum tariffs). (modified by the increase in steel and aluminum tariffs to now state that if tariffs under (d) or (e) apply, then no tariffs pursuant to (b) or (c) apply
  • If tariffs under (d) apply, (e) tariffs may also be applied to those goods (if the ordinary conditions are met). (Stacking is possible on aluminum and steel tariffs)
  • If tariffs under (e) apply, (d) tariffs may also be applied to those goods (if the ordinary conditions are met). (Stacking is possible on aluminum and steel tariffs)

The rest of the order basically says everything else but the above is UNCHANGED. 10% Reciprocal tariffs on every country except China, China 125% Reciprocal Tariff, IEEPA/Fentanyl Tariff on China of 20%, Section 301 China tariffs of 7.5% to 100%, etc.

Manufacturer’s and importers of record may apply for an offset, as detailed in the following proclamation which amends the original executive order about the auto tariffs.

Importers may seek refunds stacked duties they once paid via Post Summary Corrections or protests under 19 U.S.C. § 1514. The Federal Register notice is available here.

Tariff Stacking Questions?

Do you have questions about the stacking of tariffs and this latest Executive Order? We have answers for you. Great Lakes Customs Law has been advising importers for more than 15 years. Call us at (734) 855-4999 or fill out the form below:

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Last updated: June 5, 2025 at 11:41 am

President Trump signs proclamation imposing tariffs on imported steel and aluminum

Section 232 Steel and Aluminum Tariffs (2025)

Posted by Jason P. Wapiennik on

On February 10, 2025, President Trump signed the  following proclamations (executive orders) increasing Section 232 steel and aluminum tariffs:

  • Aluminum Imports Into U.S.; Adjustments (Proc. 10895), 9805–9816 [2025–02832] [TEXT] [PDF]
  • Steel Imports Into U.S.; Adjustments (Proc. 10896), 9817–9830 [2025–02833] [TEXT] [PDF]

This proclamation builds on — or amends and replaces – the 2018 orders and places 25% tariffs on steel and aluminum articles and certain derivatives. The 25% has since been increased to 50%.

On March 3, the Industry and Security Bureau (BIS) published the following details, which amend the HTSUS and provide instructions for tariffs on derivatives:

For aluminum:

Implementation of Duties on Aluminum Pursuant to Proclamation 10895 Adjusting Imports of Aluminum into the United States

For steel:

Implementation of Duties on Steel Pursuant to Proclamation 10896 Adjusting Imports of Steel into the United States

Here are some highlights:

  • Changes take effect March 12, 2025
  • Raises aluminum tariff from 10% to 25%
  • The exclusion portal is closing and no new exclusions will be entertained
  • General exclusions are revoked
  • Specific exclusions will be allowed to expire and but cannot be renewed
  • New tariffs can be avoided if the articles or derivatives are made from steel “melted and poured” and aluminum “smelted and cast” in the United States
  • Steel and aluminum derivatives outside of those in Chapter 76 and 73 of the HTSUS will have the value of their steel or aluminum content subject to these tariffs
  • Eliminates country-based exceptions and differences for steel imports
  • Increases enforcement and scrutiny of aluminum and steel imports by CBP, attempts to eliminate mitigation of maximum assessed penalties
  • Additional steel or aluminum derivatives can be added to the list by request of a producer or industry association, after approval from Commerce
  • No mitigation on CBP penalties for misclassification
  • Empty aluminum and beer cans are included (by order here)
Last updated: September 14, 2025 at 19:13 pm

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Steel & Aluminum Tariff Exclusions (Section 232)

Posted by Jason P. Wapiennik on

Section 232 Tariffs on Steel and Aluminum

President Trump imposed tariffs on imports of certain steel mill and aluminum aluminum articles from most countries.  bases; first, he imposed a and 10% aluminum tariff under section 232 of the Trade Expansion Act of 1962. Section 232 allows the President to impose tariffs for national security reasons. The full reports and recommendations prepared by Secretary Wilbur Ross are available here.

Steel Tariffs

The steel tariffs of 25% steel tariff are imposed against all countries of origin (not export), except Argentina, Australia, Brazil, and South Korea. A tariff of 50% is imposed on the same articles when the country of origin is Turkey.

Aluminum Tariffs

The aluminum tariffs of 10% are imposed against all countries of origin (not export), except Argentina and Australia.

South Korean Absolute Quota

Even though there is no additional duty from steel imported from South Korea, there is an absolute quota. That means that no imports may be entered into the United States for consumption (i.e., use) when the quota is met. Recently, however, the Commerce Department has opened up the exclusion process (discussed below) for goods which cannot be imported due to the absolute quota.

Section 232 Exclusion Requests

The section 232 tariffs on steel and aluminum permit importers to request exclusions from certain products, on certain grounds. Initially, the official announcements and proclamations seemed to only permit exclusion requests on national security grounds, however, once the exclusion request form (steel) was published it seemed to permit exclusion requests to be filed for basically any reason (including insufficient U.S. availability, No U.S. Production, and “Other”).

In August 2018, the President expanded the exclusion program to allow requests to be excluded from the absolute quota imposed against South Korean steel. The exclusion requests will be granted to affected parties in the United States if:

  • the steel is not domestically produced in a sufficient or reasonably available amount or of a satsifactory quality; or,
  • specific national security considerations.

The government will also considered logistical challenges, such as the “ability to transport articles with the United States, and any other factors as the Secretary deems appropriate.”

The government is also allow for exclusions from absolute quota for steel to be used in the construction of a facility ordered under a contract dated before March 8, 2018, and the steel cannot be procured domestically.

Importers may be in a panic about the tariffs; they should not. We have successfully obtained exclusions on behalf of our clients for steel products.

Therefore, they should calmly consider requesting exclusions for the products so that the new tariffs will not apply to them, and they will not be required to pay the extra duties. Although the exclusion process can be done by anyone, as always, hiring an experienced attorney to advocate for the exclusion of the particular products will help to ensure the best result possible.

Warning: This information on this page is subject to our general disclaimer, and only current through Last updated: December 22, 2024 at 11:15 am. For legal advice, please contact us for a consultation.

Want to discuss a possible section 232 exclusion?

If you want to discuss a possible 232 exclusion request, and are interested in applying for an exclusion for section 232 tariffs, you can give us a call.

President Trump signs proclamation imposing tariffs on imported steel and aluminum

Exclusion requests for Sec 232 and 301 tariffs

Posted by Jason P. Wapiennik on

Section 232 Tariffs: Steel, Aluminum, China

President Trump has announced new tariffs this year imposed on imports from various countries under two bases; first, he imposed a 25% steel tariff and 10% aluminum tariff under section 232 of the Trade Expansion Act of 1962. This section allows the President to impose tariffs for national security reasons. We have a more extensive analysis at our page Steel & Aluminum Tariff Exclusions (Section 232)

Second, President Trump announced Section 301 tariffs against China ranging from 10% to 25%. We have a more extensive analysis at our page Section 301 Tariff Exclusions (China).

To date, the fact that these tariffs might only end-up hurting domestic industries is getting a lot of attention (there is a lot of tariff activity). There seems to be little awareness or recognition — both amongst importers and the news community as a whole — that there is very large loophole in both new tariffs: exclusions.

Exclusion Requests

The section 232 tariffs on steel and aluminum permit importers to request exclusions from certain products, on certain grounds. Initially, the official announcements and proclamations seemed to only permit exclusion requests on national security grounds, however, once the exclusion request form (steel) was published it seemed to permit exclusion requests to be filed for basically any reason (including insufficient U.S. availability, No U.S. Production, and “Other”).

Importers may be in a panic about the new tariffs; they should not. They should calmly consider requesting exclusions for the products so that the new tariffs will not apply to them, and they will not be required to pay the extra duties. Although the exclusion process can be done by anyone, as always, hiring an experienced attorney to advocate for the exclusion of the particular products will help to ensure the best result possible.

Want to discuss a possible section 232 exclusion?

If you’re interested in applying for an exclusion for section 232 or 301 tariffs, you can give us a call or complete the contact form below.

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