On March 8, President Trump officially signed proclamations imposing a 25 percent tariff on imported steel and a 10 percent tariff on imported aluminum pursuant to Section 232(b) of the Trade Expansion Act of 1962.

The signing of the proclamations came exactly one week after the president abruptly announced his decision to impose the global tariffs during a White House meeting with key steel and aluminum executives.

The effective date of the tariffs is March 23, exactly 15 days after the official announcement.

The proclamations provide for Country Exemptions and Product Exclusions.

Country Exemptions

The tariffs apply to steel and aluminum imported from all countries. However, Mexico and Canada are exempt from the tariffs. Certain other countries with which the United States has “a security relationship” may be eligible for a similar exemption. No countries are listed and the term “security relationship” is undefined. The U.S. Trade Representative, Ambassador Robert Lighthizer, will lead negotiations with countries seeking such exemptions. A timeframe for such discussions has not been announced.

Product Exclusions

The specific procedure to seek product exclusions has not yet been announced. The proclamations require it to be “issued within 10 days,” which is March 18. The Department of Commerce, in coordination with other agencies including the Department of Defense and the U.S. Trade Representative, is responsible for creating the procedures, as well as reviewing and approving submitted product exclusion requests.

The proclamations included certain requirements for product exclusions.

First, an exclusion request may only be made by “a directly affected party located in the United States.” Thus, foreign entities appear ineligible to submit the request.

Second, the following criteria are listed for exclusion requests:

  1. An eligible requestor must show a product is not produced in the United States in a sufficient and reasonably available amount, or of a satisfactory quality.
  2. The request must be based on specific national security considerations.

Country Retaliation

Shortly after the president announced his decision to impose a global tariff on steel and aluminum imports, the President of the European Commission, Jean-Claude Juncker, drafted a proposal for dispute settlement consultations with the United States. Other countries also announced retaliation on U.S. exports including Kentucky bourbon, orange juice, Levi jeans, Harley-Davidson motorcycles, and certain steel products under Chapters 72 and 73 of the Harmonized Tariff Schedule. This sets the stage for international negotiations.

To keep up with the latest developments on the Section 232 steel and aluminum investigations and tariffs, please click here to subscribe to the blog’s Section 232 Investigations section.

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Photo of Robert L. LaFrankie Robert L. LaFrankie

Robert L. LaFrankie is a partner in Crowell & Moring’s International Trade Group and resident in the firm’s Washington, D.C. office. Bob regularly advises manufacturers, exporters, and importers in all aspects of international trade and customs proceedings before various government agencies, courts, and…

Robert L. LaFrankie is a partner in Crowell & Moring’s International Trade Group and resident in the firm’s Washington, D.C. office. Bob regularly advises manufacturers, exporters, and importers in all aspects of international trade and customs proceedings before various government agencies, courts, and international tribunals. He focuses on trade-related litigation and counseling, including trade remedy proceedings and U.S. Customs compliance and enforcement issues. Bob has successfully defended numerous clients located throughout Asia, Europe, and the Americas that produce or import a diverse range of products, including flat-rolled and specialty steel products and components, chemicals and plastics, frozen and canned food products, paper products, motor vehicle parts and components, specialty valves and valve systems, disposable lighters, petrochemical and renewable fuels, anti-friction bearings, and other manufactured products. In addition to litigation and compliance counseling, Bob engages in strategic trade remedy and customs planning activities for clients, particularly for companies with global sourcing, manufacturing, and export/import operations. He also advises companies with regard to NAFTA compliance issues and related audits of client facilities.

Photo of J. Chris Haile J. Chris Haile

J. Chris Haile is a partner at Crowell & Moring with extensive experience in government procurement law. Mr. Haile litigates disputes and counsels clients in a broad range of government contract matters, with particular emphasis on the resolution of contract disputes. For example…

J. Chris Haile is a partner at Crowell & Moring with extensive experience in government procurement law. Mr. Haile litigates disputes and counsels clients in a broad range of government contract matters, with particular emphasis on the resolution of contract disputes. For example, Mr. Haile has represented clients in matters involving the government’s breach of contract, claims for contract changes, termination for default, termination for convenience, Truth in Negotiations Act (TINA) compliance and defective pricing, commercial-item procurement, contract negotiations, and bid protests. He also represents clients in other related matters, such as investigations and audits by government agencies or inspectors general (IGs), False Claims Act / qui tam relator suits, and disclosures to the U.S. Government.