As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2025, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs. Customs and Border Protection (CBP) guidance confirms that “melted and poured” / “smelted and cast” reporting is due for all steel and aluminum articles and their derivative products. All existing tariff rate quotas and general/country exclusions have been terminated as of March 11, 2025. Currently, there is no process for interested U.S. parties to seek new product exclusion requests, and all currently-in-force product exclusions will end as of their end date or when quotas are reached. These Section 232 tariffs are in addition to any other imposed duties or tariffs, including the recent IEEPA tariffs imposed against China, Mexico and Canada.
Updated CBP guidance can be found on the Cargo Systems Messaging Service (CSMS):
- CSMS # 64384496 – UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products
- CSMS # 64384423 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
- CSMS # 64375535 – Quota Guidance: Proclamation 10896 of February 10, 2025, Adjusting Imports of Steel and Aluminum into the United States
For additional background on these new tariffs on imported steel and aluminum articles and their derivative products from all countries, see Thompson Hine Updates of February 12, 2025 and February 14, 2025.
As expected, Canada and the European Union (EU) responded with countermeasures and retaliatory tariffs. The EU announced a two-step approach: (1) the end of the suspension of existing 2018 and 2020 countermeasures against the United States on April 1, 2025; and (2) a package of new countermeasures on U.S. exports to enter into force by mid-April 2025, following the consultation of EU member states and stakeholders. Canada responded with a “dollar-for-dollar” approach with 25% retaliatory tariffs on U.S. goods worth approximately $21 billion. The package of Canadian countermeasures is effective as of March 13, 2025. Canada also announced that these U.S. tariffs violate U.S. obligations under both the USMCA and the World Trade Organization (WTO) Agreement and that it will be seeking consultations with the United States as a first step in any dispute settlement under these agreements. Mexico has indicated that it may delay any retaliatory measures until April 2, 2025, when President Trump has indicated the United States will impose separate reciprocal tariffs, “to see if we also need to take some actions.”
Thompson Hine LLP’s International Trade practice group members continue to monitor these fluid and changing tariffs measures and will continue to report any significant developments.