Get Up To Date Analysis On Trump Administration Section 232 Tariffs

As Connecting the Dots reported last week, President Donald Trump announced important updates to the Section 232 tariffs on imports into the United States of steel and aluminum products. As legal experts at Holland and Knight explained, the order:

• Raised Section 232 tariffs for aluminum products from 10 percent to 25 percent.
• Made certain derivative steel and aluminum products subject to Section 232 tariffs as of March 12, 2025. (These products have not yet been defined.)
• Revoked previously negotiated country-specific exemptions and quota arrangements. As a result, all previously exempted or quota-managed countries, including Australia, South Korea, Canada, Mexico, Brazil, Japan, the United Kingdom, and the European Union, will now be subject to the full 25 percent tariff on steel and aluminum exports into the United States.
• Eliminated and modified the product exclusion process for steel and aluminum imports by removing the U.S. Department of Commerce secretary’s authority to grant relief for products deemed insufficiently available or lacking in satisfactory quality in the United States. As a result and effective immediately, this order means the secretary is barred from considering new product exclusion requests or renewing existing ones. Previously granted exclusions are valid only until their expiration dates or until the approved volume has been imported, whichever date comes first.
• Created a narrow exclusion for derivative steel products processed in another country if they originate from steel articles that were melted and poured in the United States. There also is a narrow exclusion for derivative aluminum products processed in another country if they originate from aluminum articles that were smelted and cast in the United States.
• Mandated that, by May 11, 2025, the U.S. Commerce secretary establish a process allowing U.S. steel and aluminum producers and the industry associations representing them to request the inclusion of additional derivative products under the Section 232 tariffs.

The National Law Review has more information at this link. Read the White House’s proclamation regarding aluminum at this link, its proclamation regarding steel at this link, and its fact sheet regarding both orders at this link. Officials from Canada, the European Union, and Mexico all have criticized the announcement, but so far none have outlined specific retaliatory measures.

As a reminder, while the Metals Service Center Institute (MSCI) supports actions to address unfair trade practices by countries that continually circumvent international rules, as a trade association representing firms throughout North America, our organization and its leadership have continually argued shipments from Canada and Mexico should be exempt from these penalties. Please find our 2017 testimony articulating this position at this link.