Dear Colleagues,
On June 3, 2025, the White House issued a Presidential Proclamation raising Section 232 tariffs steel and aluminum products from 25% to 50%, effective June 4, 2025 at 12:01 AM EDT. This update requires immediate action from importers and brokers to ensure proper entry filing and compliance with CBP regulations.
Section 232 Steel & Derivative Tariffs New Duty Rates EFFECTIVE 6/4/25
CSMS # 65236374
- 50% Section 232 duty applies to all affected steel/derivative imports from all countries.
- 25% duty continues for UK-origin goods.
Effective Date: Applies to entries for consumption or FTZ withdrawals on or after June 4, 2025, 12:01 AM EDT.
U.S. Melted & Poured Steel: Derivative steel items made from steel melted and poured in the U.S. may qualify for 0% duty (HTS 9903.81.92).
Entry Filing Requirements:
If Steel Value Is Known, use two entry lines as follows:
- Line 1 – Non-Steel Content: HTS 1–97, origin, total quantity, non-232 duties.
- Line 2 – Steel Content: Same HTS 1–97, same origin, 0 quantity, steel value, 232 duty under Chapter 99 + steel content weight in kg.
If the steel value is unknown or equals the total entered value, file as a single line applying the full value to the Section 232 duty.
FTZ-Specific Rules:
- FTZ entries before June 4, 2025 must be in privileged foreign status to retain earlier duty rate.
- FTZ entries on/after June 4, 2025 must also be admitted under privileged foreign status and will be subject to the new 50% or 25% duty upon withdrawal.
Melt and Pour reporting is mandatory: use the ISO country code indicating the country where the steel was originally melted and poured
Reciprocal Tariffs (HTS 9903.01.25): May apply to non-steel content lines. Steel content lines under Section 232 are exempt.
No Drawback Allowed: Section 232 duties are non-refundable under drawback claims.
New Rates for Chapter 76 Aluminum Imports and Derivatives EFFECTIVE 6/4/25
CSMS #65236645
- 50% Section 232 duty applies to all affected aluminum/derivative imports from all countries.
- 25% duty continues for UK-origin goods.
- Duties must be based on aluminum content value, not total product value.
If the aluminum value is less than total value:
Line 1: Report non-aluminum content with HTS Chapters 1 through 97 (include regular duties).
Line 2: Report aluminum content with:
- Same Ch. 1–97 HTS
- Add Ch. 99 HTS for 232 (e.g., 9903.85.08, .15)
- Quantity = 0 for HTS, report kg aluminum for Ch. 99
- Apply Section 232 duty to aluminum value only
Russian-Origin Aluminum: 200% duty still applies via HTS 9903.85.67 (products) and 9903.85.68 (derivatives). Applies if any smelting or casting was in Russia.
U.S.-Origin Exemptions: HTS 9903.85.09 allows 0% duty if aluminum was smelted & cast in the U.S. (applies to derivatives).
Smelt & Cast Reporting (Required for All Countries):
Report ISO country codes for:
- Primary smelt (Y/N)
- Secondary smelt (Y/N)
- Country of cast
Reciprocal Tariffs:
- Non-aluminum content lines may trigger EO 14257 duties (HTS 9903.01.25).
- Aluminum content lines are excluded from reciprocal tariff application.
Key Differences for Aluminum Rules
The new Section 232 rules for aluminum imports, outlined in CSMS #65236645, bring some important changes that differ from the earlier guidance on steel. While both aluminum and steel tariffs are going up from 25% to 50% starting June 4, 2025, the aluminum update includes a few specific details that set it apart.
RESOURCE LINKS:
- HTS: Harmonized Tariff Schedule
- CSMS: Cargo Systems Messaging Service
- E.O.: Executive Orders
- IEEPA FAQs
- 232 FAQs
- TARIFF STACKING CHART
- TARIFF NUMBER SPREADSHEET
2025 ADDITIONAL TRADE REMEDY TARIFF FLOW CHART
IEEPA FENTANYL TARIFFS
China, Mexico & Canada
Process Flow:
- Is the product origin China, Canada, or Mexico?
- If China: Additional 20% tariff applies
- If Canada or Mexico: Check if it qualifies for USMCA
- If Yes: No additional tariff applies
- If No, Canada origin: Additional 25% tariff applies
- If No, Mexico origin: Additional 25% tariff applies
- Is the product potash?
- If Yes: Additional 10% tariff applies
- Is the product an energy resource?
- If Yes: Additional 10% tariff applies
- If No: Additional 25% tariff applies
IEEPA RECIPROCAL TARIFFS
All Countries
Effective April 5, 2025: Additional 10% tariff will apply.
- If at least 20% of the product’s value is U.S. originating, the tariff rate will only apply to the non-U.S. content.
Additional Tariff 10% as new tariffs paused for 90 days. Effective July 9, 2025: Additional tariff will increase from 10% to the rate specified in Annex I, ranging from 11% to 50%.
- If at least 20% of the product’s value is U.S. originating, the tariff rate will only apply to the non-U.S. content.
Exemptions: Does the product fall into at least one of the following categories?
- Product of Canada or Mexico
- Articles identified in Annex II (e.g., copper, pharmaceuticals, semiconductors, lumber articles, critical minerals, and energy and energy products)
- Articles already subject to section 232 steel and aluminum tariffs
- Articles already subject to section 232 automotive tariffs
- Articles subject to the Column 2 rate of duty (i.e., products of Belarus, Cuba, North Korea, or Russia)
- Bullion
- Energy or minerals that are not available in the U.S.
If Yes to any: No additional tariff applies.
Section 232 Automotive
Process:
- Is this product an automobile or automobile part identified in the annex?
- If No: No additional tariff applies
- If Yes: Does it qualify for USMCA?
- If Yes (Automobile): Additional 25% tariff on the non-U.S. content will apply once Commerce approves the automobile’s eligibility based on importer documentation.
- If Yes (Part): Additional 25% tariff on the non-U.S. content will apply once Commerce establishes a system to calculate the non-U.S. content (no later than May 3, 2025).
- If No: Additional 25% tariff applies
Section 232 Tariffs (Steel & Aluminum)
Process Flow:
- Is the product HTS on one of the aluminum or steel annexes?
- If No: No additional tariff applies
- If Yes: Continue to next step
- Is the product aluminum of UK origin or primarily smelted/cast in UK?
- If Yes: Additional 25% tariff applies
- If No: Continue to next step
- Is the product aluminum of Russian origin or primarily smelted/cast in Russia?
- If Yes: Additional 200% tariff applies
- If No: Continue to next step
- Is the product classified in Chapter 73 (steel) or Chapter 76 (aluminum)?
- If Yes: Additional 50% tariff applies
- If No: Continue to detailed analysis
- Are the products steel or aluminum components smelt or cast in the United States?
- If Yes: No additional tariff applies
- If No: Continue analysis
- Detailed content analysis:
- Are the products listed in both steel & aluminum annexes?
- Is the products listed in the steel OR aluminum annex?
- Does the product contain steel/aluminum?
Results based on content:
- Steel content: Additional 50% tariff applies to the steel content
- Aluminum content: Additional 50% tariff applies to the aluminum content
- Both: Additional 50% tariff applies to the steel and aluminum content
- Neither: No additional tariff applies
CHINA TARIFFS (includes Hong Kong & Macau)
301, IEEPA Fentanyl, 232 & IEEPA Reciprocal
Complex tariff stacking applies based on:
- Country of Origin (China, Hong Kong, or Macau)
- Section 301 China tariffs applicability
- Section 232 (steel & aluminum) tariffs applicability
- HTS classification on Annex II
Possible combinations:
- 301 duty rate (7.5-25%) + IEEPA Fentanyl 20%
- 301 duty rate (7.5-25%) + IEEPA Fentanyl 20% + 232 (steel & aluminum) 50%
- 301 duty rate (7.5-25%) + IEEPA Fentanyl 20% + 10% IEEPA Reciprocal
- 20% IEEPA Fentanyl + 232 (steel & aluminum) 50%
- 20% IEEPA Fentanyl + 10% IEEPA Reciprocal
Important Note: If HTS is on Annex II or subject to Section 232 then IEEPA Reciprocal (125%) does NOT apply to the 232 content value only.
