Overview This memo outlines two significant updates from U.S. Customs and Border Protection (CBP) regarding Section 232 tariffs on aluminum and steel imports, effective June 2025. These changes may impact import compliance, cost structures, and supply chain planning.
1. 200% Tariff on Aluminum with Unknown Country of Smelt and Cast Effective June 28, 2025, derivative aluminum imports with an unknown or indeterminable country of smelt and cast will be subject to a 200% Section 232 tariff—equivalent to the duty rate for Russian-origin aluminum.
- Importers must report “UN” (unknown) in the smelt and cast country fields.
- HTS codes 9903.85.67 or 9903.85.68 must be used, as applicable.
- This policy reinstates CBP’s March 2025 guidance, which was briefly paused.
- Importers may later file a Post Summary Correction (PSC) if they can verify that the aluminum did not originate from Russia.
Action Required: Review your aluminum sourcing and ensure accurate documentation of smelt and cast origins to avoid the 200% duty.
2. Expansion of Section 232 Duties on Steel Consumer Appliances Effective June 23, 2025, CBP has expanded Section 232 duties to include a broader range of steel consumer appliances, such as:
- Washing machines
- Refrigerators
- Dishwashers
These products are now subject to a 50% duty rate, applied to the value of steel content in each item.
U.K.-origin steel and aluminum remain exempt from the 50% rate and are instead subject to a 25% tariff.
Action Required: Evaluate your product classifications and steel content to determine exposure to the new duty rates.
Next Steps We recommend the following:
- Audit your import data for aluminum and steel products.
- Coordinate with suppliers to obtain accurate smelt and cast documentation.
- Consult with trade compliance experts to assess tariff exposure and explore mitigation strategies.
For further guidance or assistance, please contact our Trade Compliance Team at compliance@coppersmith.com.
3. Timeline of Reciprocal Tariff Events This document outlines the key upcoming dates related to reciprocal tariffs. The timeline highlights important events and deadlines that may impact tariff rates and trade agreements.
Key Dates:
- July 9, 2025:
- Expiration of the 90-day reciprocal tariff pause. Duties will revert to higher reciprocal based on latter of arrival or entry date unless further extended.
- Postponed 50% tariff on EU may take effect if no extension is announced
- August 11, 2025:
- Deadline for implementation of the U.S.-China trade deal
- If not implemented, reciprocal tariffs on Chinese goods may revert to 34%
Victoria Lane
Chief Compliance Officer
L.E. Coppersmith LLC
