The landscape of steel and aluminum tariffs is undergoing significant changes, with new regulations set to take effect on March 12, 2025. These updates will impact imports of steel and aluminum products, along with specified derivative products, imposing a 25% tariff across all countries.
Expanded Tariff Scope for Derivative Products
An expanded list of derivative products will also be subject to tariffs. However, the enforcement of these tariffs is contingent upon the Secretary of Commerce confirming that an adequate system is in place to process and collect duties efficiently. Further details on the affected products will be released as soon as the official annexes become available.
For steel derivatives not classified under Chapter 73 of the Harmonized Tariff Schedule of the United States (HTSUS), the tariff will apply only to the steel content of the product. Similarly, for aluminum derivatives not classified under Chapter 76, the tariff will apply only to the aluminum content of the article. Additionally, aluminum products originating from Russia will face a significantly higher tariff of 200%. This applies to primary aluminum, defined as newly produced metal from alumina via the electrolytic Hall-Heroult process.
Exemptions Based on Origin and Certification
Certain exemptions are available. If a derivative steel product is manufactured in another country but uses steel that was originally melted and poured in the United States, it may be exempt from the tariff, provided proper certification is submitted to U.S. Customs and Border Protection (CBP). Similarly, importers must furnish documentation identifying the aluminum content in derivative products. CBP will issue further guidance on the required documentation.
Cancellation of Previous Trade Agreements and Exclusions
As of March 12, all prior steel and aluminum agreements with key trading partners—including Argentina, Australia, Brazil, Canada, the European Union, Japan, Mexico, South Korea, Ukraine, the United Arab Emirates, and the United Kingdom—will be terminated. Steel products and derivatives from Turkey will face a higher tariff of 50%.
No new exclusions or exemptions will be granted after February 11, and all previously approved exclusions will end on March 12. However, existing exclusions will remain valid until their expiration date or until the allocated volume is exhausted.
Future Tariff Adjustments and Product Inclusions
The Commerce Department has been directed to establish a process within 90 days for adding new products to the list of tariffed items. Domestic steel and aluminum producers, along with industry associations, may petition to include additional products, with decisions being made within 60 days of a request.
Enforcement and Compliance Measures
No duty drawbacks will be permitted on these tariffs. CBP is prioritizing the classification review of steel and aluminum products to ensure compliance. Any misclassification aimed at avoiding tariffs will result in strict penalties, without consideration of mitigating factors. These penalties may be subject to judicial review.
For aluminum, CBP will also assess monetary penalties at the maximum amount allowed by law for misclassification. Additionally, steel and aluminum products or their derivatives admitted into foreign trade zones on or after March 12 must be categorized as “privileged foreign status” unless eligible for admission under “domestic status.” This classification will ensure they are subject to tariffs upon entry for consumption.
Final Thoughts
These regulatory updates mark a significant shift in trade policies for steel and aluminum imports. Businesses engaged in importing these materials should take proactive steps to ensure compliance with certification requirements and classification guidelines to avoid unexpected costs and penalties. Staying informed and preparing for these changes will be crucial for maintaining smooth trade operations in the months ahead.
