U.S. Section 232 Tariffs on Aluminum and Steel Imports and Reciprocal Trade and Tariffs Plan

February 2025

U.S. Section 232 Tariffs on Aluminum and Steel Imports and Reciprocal Trade and Tariffs Plan, February 2025

On February 10 and 13, 2025, U.S. President Donald J. Trump signed documents that will increase tariffs on imports of aluminum and steel and may increase tariffs on imports of a variety of other products to the U.S. On February 10, President Trump signed proclamations that establish a 25% additional tariff rate on imports of selected aluminum and steel products to the U.S. On February 13, the president signed a memorandum announcing a plan under which the U.S. government ultimately could apply “the equivalent of a reciprocal tariff” to imports from each of the U.S.’s foreign trading partners.

The three documents reference national security concerns as a basis for presidential action. The legal basis for the aluminum and steel tariff increases is Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). Section 232 enables the president to restrict imports of an article and its derivatives based on U.S. Commerce Department findings and presidential concurrence that an item is being imported to the U.S. in quantities or under circumstances that threaten to impair U.S. national security. The Reciprocal Trade and Tariffs Memo states that the U.S. trade deficit, which the memo attributes in part to “unfair and unbalanced trade” with and “lack of reciprocity of” U.S. foreign partners, “threatens [U.S.] economic and national security…”

In general, the tariff measures described in the three documents have not yet gone into effect. The aluminum and steel duty increases will go into effect on or after March 12, 2025, while any measures that may be issued under the plan in the Reciprocal Trade and Tariffs Memo would not go into effect until after August 12, 2025. This is the date by which the Director of the U.S. Office of Management and Budget (OMB) is to deliver to the president an assessment in writing of the fiscal impact of “non-reciprocal trade” and proposed remedies on the federal government.

Nevertheless, it is important for companies participating in international trade in or with the U.S. to understand how duties that apply to the products in which they do business may change in the upcoming months based on these presidential actions.

Section 232 Aluminum Import Adjustments

On February 10, 2025, the president signed Proclamation 10895 “Adjusting Imports of Aluminum Into the United States.” It was published in the Federal Register as 2025-02832 (90 FR 9807) on February 18.

Elimination of Exemptions

Proclamation 10895 eliminates exemptions for a number of countries with which the U.S. has a security relationship from Section 232 ad valorem tariffs and related restrictions on imports of aluminum articles that were established in Proclamation 9704 of March 8, 2018, Proclamation 9880 of January 4, 2020, and subsequent proclamations.

Proclamation 10895 renders the following previously issued proclamations or provisions of proclamations ineffective as of 12:01 a.m. Eastern Time (ET) on March 12, 2025:

  • Proclamation 9758 (2018) with respect to imports of aluminum articles from Argentina and Australia;

  • Proclamations 9893 (2019) and 10106 (2020) with respect to imports of aluminum articles from Canada;

  • Proclamations 9893 (2019) and 10782 (2024) with respect to imports of aluminum articles and derivative aluminum articles from Mexico;

  • Proclamations 10327 (2021) and 10690 (2024) with respect to imports of aluminum articles and derivative aluminum articles from the European Union (EU);

  • Proclamation 10405 (2022) with respect to imports of aluminum articles and derivative aluminum articles from the United Kingdom (UK); and

  • Clause 1 of Proclamation 9880 (2020) as applicable to imports of derivative aluminum articles from Argentina, Australia, Canada, and Mexico.

Increases in Duty Rates and Dates of Effect

Proclamation 10895 further provides for the following:

  • As of 12:01 a.m. ET on March 12, 2025, the tariff rates proclaimed in Proclamations 9704 and 9880, as amended, will increase from an additional 10% ad valorem to an additional 25% ad valorem;

  • As of 12:01 a.m. ET on March 12, 2025, imports of aluminum articles from all countries except Russia, including Argentina, Australia, Canada, Mexico, the EU countries, and the UK, will be subject to the additional ad valorem tariffs proclaimed in Proclamations 9704 and 9880, as amended, at the revised tariff rate of 25% ad valorem, which is in addition to any other duties, fees, exactions, or charges that apply; and

  • On or after 12:01 a.m. ET on March 12, 2025, imports of derivative aluminum articles from all countries except Russia will be subject to the revised 25% ad valorem duty rate, which is in addition to any other duties, fees, exactions, or charges that apply.

Articles Affected

The articles of aluminum currently subject to the additional 10% duty rate when entered for consumption or withdrawn from warehouse for consumption, and which presumably will be subject to the revised 25% rate, are identified in Proclamation 9704, as amended, and the Harmonized Tariff Schedule of the United States (HTSUS), which lays out the tariff rates and statistical categories for all goods imported to the U.S. These items are:

  • Unwrought aluminum - HTSUS 7601;

  • Aluminum bars, rods, and profiles - HTSUS 7604;

  • Aluminum wire - HTSUS 7605;

  • Aluminum plates, sheets, and strip - HTSUS 7606;

  • Aluminum foil - HTSUS 7607;

  • Aluminum tubes, pipes, and tube or pipe fittings - HTSUS 7608 and 7609; and

  • Aluminum castings and forgings - HTSUS 7616.99.51.

Goods entered for consumption are goods imported to the U.S. for commercial, business, or personal use that go directly into U.S. commerce without any time or use restrictions.

Goods withdrawn from warehouse for consumption are items imported to the U.S. and placed, without payment of duties at that time, in a bonded warehouse for purposes such as storage, repacking, or sorting and which are later withdrawn from the warehouse for use.

The derivative aluminum articles currently subject to the additional 10% duty rate when entered for consumption or withdrawn from warehouse for consumption, and which presumably will be subject to the revised additional 25% rate, are identified in Proclamation 9880, as amended, and the HTSUS. These items are:

  • Stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles - HTSUS 7614.10.50;

  • Stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing comprising electrical conductors, not fitted with fittings or made up into articles - HTSUS 7614.90.20;

  • Stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing not comprising electrical conductors, not fitted with fittings or made up into articles - HTSUS 7614.90.40;

  • Stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles - HTSUS 7614.90.50;

  • Bumper stampings of aluminum, the foregoing comprising parts and accessories of the motor vehicles of HTSUS 8701 to 8705 - HTSUS 8708.10.30; and

  • Body stampings of aluminum, for tractors suitable for agricultural use - HTSUS 8708.29.21.

Annex I to Proclamation 10895 lists 123 other HTSUS classifications of derivative aluminum articles that will be subject to the additional 25% ad valorem rate of duty when entered for consumption or withdrawn from warehouse for consumption. These classifications appear in Chapters 66, 76, 83-85, 87, 88, 90, and 94-96 of the HTSUS.

The additional 25% duty rate will take effect for some of the derivative aluminum articles listed in Annex I of Proclamation 10895 on March 12, but it may not become effective for other items until after that date. The additional 25% duty rate will apply to 10895-listed items in Chapter 76 starting at 12:01 a.m. ET on March 12. The additional 25% duty rate will apply to 10895-listed items that are not in Chapter 76 upon public notification by the Secretary of Commerce that adequate systems are in place to “fully, efficiently, and expediently process and collect tariff revenue for covered articles.”

Exceptions to the 25% Additional Duty Rate

Proclamation 10895 provides for several exceptions to the application of the additional 25% duty rate to 10895-listed derivative aluminum articles:

  • For 10895-listed items that are not in Chapter 76 of the HTSUS, the additional ad valorem duty will apply only to the aluminum content of the derivative article;

  • The additional ad valorem duty will not apply to 10895-listed derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the U.S.;

  • All imports of 10895-listed derivative aluminum articles that are the product of Russia and are entered for consumption or withdrawn from warehouse for consumption on or after the Commerce notification date are subject to a 200% ad valorem rate of duty (established in Proclamation 10522 of February 24, 2023);

  • All imports of 10895-listed derivative aluminum articles in which any amount of primary aluminum used in the manufacture of the derivative aluminum article was smelted in Russia and are entered for consumption or withdrawn from warehouse for consumption on or after the Commerce notification date are subject to the 200% duty; “primary aluminum” is defined in Proclamation 10895 as “new aluminum metal that is produced from alumina (or aluminum oxide) by the electrolytic Hall-Heroult process;” and

  • All imports of 10895-listed derivative aluminum articles that are cast in Russia and are entered for consumption or withdrawn from warehouse for consumption on or after the Commerce notification date are subject to the 200% duty.

Traders should note that imports from Russia of aluminum articles listed in Proclamation 9704, as amended, and derivative aluminum articles listed in Proclamation 9880, as amended, are already subject to the 200% additional duty rate that was established in Proclamation 10522 (2023).

Other Restrictions, Enforcement, and Implementation

Additionally, Proclamation 10895 tightens or will tighten restrictions on imports of aluminum articles and derivative aluminum articles in the following ways:

  • The Secretary of Commerce will not consider any new product exclusion requests or renew any product exclusions in effect as of the date of the proclamation (February 10, 2025);

  • While already-granted product exclusions are to remain effective until their expiration date or until the excluded product volume is imported (whichever occurs first), the Commerce Secretary will take all actions necessary to terminate the product exclusion process;

  • All general approved exclusions will be ineffective as of March 12, 2025;

  • Importers of aluminum derivative articles will be required to provide U.S. Customs and Border Protection (CBP) with any information necessary to identify the aluminum content used in the manufacture of aluminum derivative article imports covered by the proclamation;

  • Within 90 days of the publication date of Proclamation 10895, the Secretary of Commerce will establish a process for including additional derivative aluminum articles in the scope of the Section 232 duties;

  • Any provisions of previous proclamations enabling the Commerce Secretary to grant relief for certain products from the additional duties generally are revoked;

  • Any aluminum article or derivative aluminum article subject to the duty imposed in the proclamation that is admitted to a U.S. foreign trade zone on or after the Commerce notification date may be admitted only under “privileged foreign status,” unless it is eligible for admission under “domestic status;” upon entry for consumption, the item will be subject to the appropriate duty rates for the item’s HTSUS classification; and

  • No drawback will be available with respect to the duties imposed in the proclamation. Drawback is the refund of certain duties, taxes, and fees for some imported goods that are later exported or destroyed.

Proclamation 10895 addresses enforcement. It requires CBP to prioritize reviews of the classification of imported aluminum articles and derivative aluminum articles. If CBP discovers misclassification resulting in loss of revenue from the ad valorem duties, CBP must assess monetary penalties “in the maximum amount permitted by law.”

Within 10 days of the proclamation’s publication, the U.S. International Trade Commission, in consultation with other U.S. government agencies, will revise the HTSUS to reflect the amendments and effective dates in the proclamation.

Section 232 Steel Import Adjustments

Also on February 10, 2025, the U.S. president signed Proclamation 10896 “Adjusting Imports of Steel Into the United States.” It was published in the Federal Register on February 18 as 2025-02833 (90 FR 9817).

Elimination of Exemptions

Proclamation 10896 eliminates exemptions for several countries with which the U.S. has a security relationship from Section 232 ad valorem tariffs and other restrictions on imports of steel articles that were established in Proclamation 9705 of March 8, 2018, Proclamation 9880 (2020), and subsequent proclamations. Proclamation 10896 makes the following proclamations ineffective as of 12:01 a.m. ET on March 12, 2025:

  • Proclamation 9740 (2018) with respect to imports of steel articles from South Korea;

  • Proclamation 9759 (2018) with respect to imports of steel articles from Argentina, Australia, and Brazil;

  • Proclamation 10064 (2020) with respect to imports of steel articles from Brazil;

  • Proclamation 9894 (2019) with respect to imports of steel articles from Canada;

  • Proclamations 9894 (2019) and 10783 (2024) with respect to imports of steel articles from Mexico;

  • Proclamations 10328 (2021) and 10691 (2024) with respect to imports of steel articles and derivative steel articles from the EU;

  • Proclamation 10356 (2022) with respect to imports of steel articles and derivative steel articles from Japan;

  • Proclamation 10406 (2022) with respect to imports of steel articles and derivative steel articles from the UK;

  • Proclamations 10403 (2022), 10588 (2023), and 10771 (2024) with respect to steel articles and derivative steel articles from Ukraine;

  • Clause 1 of Proclamation 9740 (2018) as applicable to imports of steel articles or derivative steel articles from Argentina, Australia, Brazil, Canada, Mexico, South Korea, and EU member countries; and

  • Clause 1 of Proclamation 9880 (2020) as applicable to imports of derivative steel articles from Argentina, Australia, Canada, Mexico, and South Korea.

Application of Duty Rate and Dates of Effect

Proclamation 10896 further provides for the following:

  • On or after 12:01 a.m. ET on March 12, 2025, all imports from all countries of steel articles covered by HTSUS Heading 9903.80.01, in Sub-Chapter III of Chapter 99 of the HTSUS, will be subject to an additional 25% ad valorem duty rate with respect to goods entered for consumption or withdrawn from warehouse for consumption; and

  • On or after 12:01 a.m. ET on March 12, 2025, all imports from all countries of derivative steel articles identified in Annex I to Proclamation 10896 will be subject to the additional 25% ad valorem rate of duty with respect to goods entered for consumption or withdrawn from warehouse for consumption.

In both cases, the 25% duty rate is in addition to any other duties, fees, exactions, or charges that apply to the articles.

Articles Affected

The articles of steel currently subject to the Section 232 25% duty rate when entered for consumption or withdrawn from warehouse for consumption, and which presumably will continue to be subject to the 25% rate, are identified in Proclamation 9205, as amended, and the HTSUS:

  • Flat-rolled products provided for in HTSUS 7208, 7209, 7210, 7211, 7212, 7225, or 7226;

  • Bars and rods provided for in HTSUS 7213, 7214, 7215, 7227, or 7228;

  • Angles, shapes, and sections of HTSUS 7216 (except HTSUS 7216.61.00, 7216.69.00, or 7216.91.00);

  • Wire provided for in HTSUS 7217 or 7229;

  • Sheet piling provided for in HTSUS 7301.10.00;

  • Rails provided for in HTSUS 7302.10;

  • Fish-plates and sole plates provided for in HTSUS 7302.40.00;

  • Other products of iron or steel provided for in HTSUS 7302.90.00;

  • Tubes, pipes, and hollow profiles provided for in HTSUS 7304 or 7306;

  • Tubes and pipes provided for in HTSUS 7305;

  • Ingots, other primary forms, and semi-finished products provided for in HTSUS 7206, 7207, or 7224; and

  • Products of stainless steel provided for in HTSUS 7218, 7219, 7220, 7221, 7222, or 7223.

The derivative steel articles currently subject to the 25% duty rate when entered for consumption or withdrawn from warehouse for consumption, and which presumably will continue to be subject to the 25% rate, are identified in Proclamation 9880, as amended, and the HTSUS:

  • Nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of Heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in powder-actuated handtools, threaded - HTSUS 7317.00.30;

  • Nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of Heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of cooper), of one piece construction, whether or not made of round wire - in statistical reporting numbers 7317.00.55.03, 7317.00.55.05, 7317.00.55.07, 7317.00.55.60, 7317.00.55.80, or 7317.00.65.60 only and not in other statistical reporting numbers of 7317.00.55 and 7317.00.65;

  • Bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of Headings 8701 to 8705 - HTSUS 8708.10.30; and

  • Body stampings of steel, for tractors suitable for agricultural use - HTSUS 8708.29.21.

Annex I to Proclamation 10896 lists 167 other HTSUS classifications of derivative steel articles that will be subject to the additional 25% ad valorem rate of duty when entered for consumption or withdrawn from warehouse for consumption. These classifications appear in HTSUS Headings 7301, 7302, 7307-7326, 8431, 8432, 8547, 9403, 9405, and 9406.

The additional 25% duty rate for the derivative steel articles listed in 10896 Annex I will be effective upon public notification by the Secretary of Commerce that “adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.”

Exceptions

Proclamation 10896 provides for some exceptions to the application of the additional 25% duty to 10896-listed derivative steel articles:

  • For 10896-listed items that are not in Chapter 73 of the HTSUS, the additional ad valorem duty rate will apply only to the steel content of the derivative steel article; and

  • The additional ad valorem duty will not apply to 10896-listed derivative steel articles processed in another country from steel articles that were melted and poured in the U.S.

Other Restrictions, Enforcement, and Implementation

In addition, Proclamation 10896 tightens or will tighten restrictions on imports of steel articles and derivative steel articles in the following ways:

  • The Secretary of Commerce will not consider any new product exclusion requests or renew any product exclusion requests in effect as of 11:59 p.m. on the date of the proclamation (February 10, 2025);

  • While already-granted product exclusions are to remain in effect until their expiration date or until excluded product volume is imported, whichever occurs first, the Commerce Secretary will take all necessary action to rescind the product exclusion process;

  • The Commerce Secretary will terminate all existing general approved exclusions as of March 12, 2025;

  • Importers of steel derivative articles will be required to provide CBP with any information necessary to identify the steel content used in the manufacture of steel derivative article imports covered by the proclamation;

  • Within 90 days of the date of publication of Proclamation 10896, the Commerce Secretary will establish a process for including additional derivative steel articles in the scope of the Section 232 duties;

  • Any provisions of previous proclamations authorizing the Commerce Secretary to grant relief for certain products from the additional duties are revoked;

  • No drawback will be available with respect to the duties imposed in the proclamation;

  • Any steel article or derivative steel article subject to the duty imposed in the proclamation that is admitted to a U.S. foreign trade zone on or after 12:01 a.m. ET on March 12, 2025, must be admitted as “privileged foreign status,” unless it is eligible for admission under “domestic status;” upon entry for consumption, the article will be subject to the appropriate duty rate based on the item’s HTSUS classification; and

  • Any steel article or derivative steel article subject to the duty in the proclamation that is admitted to a U.S. foreign trade zone under “privileged foreign status” prior to 12:01 a.m. ET on March 12, 2025, will be subject to the duty rate for the applicable HTSUS classification based on the proclamation, upon the article’s entry for consumption.

However, the requirement that derivative steel articles may be admitted to a U.S. foreign trade zone only as “privileged foreign status” (unless an item is eligible for admission as “domestic status”) will not take effect for 10896-listed items until the date that the additional duties are imposed, which may be after March 12, 2025, depending on the date of the Commerce Secretary’s notification.

Proclamation 10896 references enforcement. It requires CBP to prioritize reviews of the classification of imported steel articles and derivative steel articles. If CBP discovers misclassification that led to non-payment of the ad valorem duties, CBP is to assess monetary penalties “in the maximum amount permitted by law.” Moreover, CBP must not consider any evidence of mitigating factors in its determination.

The Secretary of Commerce, in consultation with other U.S. government agencies, will review the HTSUS so that it conforms to the amendments and effective dates of the proclamation within 10 days of March 12, 2025.

The Reciprocal Trade and Tariffs Memo

On February 13, 2025, the U.S. president issued the Memorandum on “Reciprocal Trade and Tariffs.” It was published in the Federal Register as 2025-02872 (90 FR 9837) on February 19, 2025.

The Reciprocal Trade and Tariffs Memo follows the Presidential Memorandum of January 20, 2025, on the “America First Trade Policy.” The America First Trade Policy Memo included instructions for the Secretary of Commerce to investigate the causes of the U.S.’s annual trade deficit in goods and the economic and national security implications and risks of the deficit. The memo instructed the Commerce Secretary to recommend appropriate responsive measures, including with respect to tariff policies, and to assess whether it is necessary to adjust imports that threaten U.S. national security. The memo further instructed the Treasury Secretary to review and assess major U.S. trading partners’ policies and practices with respect to the rate of exchange between their currencies and the U.S. dollar, and it instructed the U.S. Trade Representative to conduct a review of “unfair trade practices by other countries.” The president instructed the officials to recommend appropriate responses and remedial actions.

The Reciprocal Trade and Tariffs Memo states that it is U.S. policy to reduce the U.S.’s annual trade deficit in goods and to address “other unfair and unbalanced aspects” of U.S. foreign trade. To do this, the memo introduces the “Fair and Reciprocal Plan” (FRP), under which the U.S. government will counter non-reciprocal trading arrangements by determining “the equivalent of a reciprocal tariff” with respect to each U.S. foreign trading partner.

These determinations will take into consideration: tariffs on U.S. products; taxes on U.S. businesses, workers, and consumers; non-tariff barriers that impact U.S. businesses, workers, and consumers; exchange-rate and other policies and practices “that make U.S. businesses and workers less competitive”; and other practices that limit U.S. market access or fair competition.

Following the submission of the various reports required under the America First Trade Policy Memo, the Secretary of Commerce and the U.S. Trade Representative will initiate all necessary actions to investigate harm to the U.S. from any trading partner’s non-reciprocal trade arrangements and propose remedies “in pursuit of reciprocal trade relations” with each partner.

Within 180 days of the date of the Reciprocal Trade and Tariffs Memo (which would be August 12, 2025), the OMB Director will deliver an assessment to the president of all fiscal impacts on the federal government of non-reciprocal trade arrangements and proposed remedies.

Persons Affected and SECURUS Services

These policies are significant and will affect many companies in or doing business with the U.S., including:

  • Companies in the U.S. that rely on foreign suppliers for aluminum, particularly in the aerospace, automotive, construction, electronics, and packaging industries;

  • U.S. importers of, companies doing business in, and consumers of a wide variety of derivative aluminum products, including: aluminum doors and ladders; cookware; parts for air conditioners, refrigerators, heaters, dishwashers, microwaves, and stoves; construction machinery; motor vehicle and aircraft parts; valves; semiconductor manufacturing machinery; circuitry-related parts and equipment; furniture; and recreational equipment;

  • Companies in the U.S. that depend on foreign suppliers for steel, especially in the aerospace, agriculture, automotive, construction, energy, manufacturing, and transportation industries;

  • U.S. importers of, companies doing business in, and consumers of derivative steel products such as: building equipment and materials; containers; barbed wire and other fencing materials; household and kitchen articles; cooking appliances; and parts for stoves, radiators, heaters, and agricultural equipment; and

  • Exporters to the U.S. of aluminum and steel products and possibly a range of other goods, depending on the extent of any reciprocal tariffs or other measures that the U.S. government implements in upcoming months.

SECURUS Strategic Trade Solutions, LLC provides guidance, training, and information to companies and individuals seeking to understand and navigate international trade rules and regulations.

If you have questions about how these policies could affect your business, please contact SECURUS Strategic Trade Solutions at Info@SECURUSTrade.com for a consultation.

Author: Richard Glen Young, Richard.Young@SECURUSTrade.com, February 20, 2025.