Section 232 Tariffs

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On August 28, 2023, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) proposed new rules to streamline and strengthen the Section 232 Exclusions Process for Steel and Aluminum imports. The proposed rules will build on the five existing interim final rules and respond to public comments received by BIS since February 2022. BIS…

On July 20, 2023, the U.S. Government Accountability Office (“GAO”) released a report titled, Steel and Aluminum Tariffs: Agencies Should Ensure Section 232 Exclusion Requests are Needed and Duties are Paid. Following an investigation analyzing import entry data from March 2018 through September 2021, GAO published a 66-page report about the usage and administration…

Customs and Border Protection (CBP) released new guidance following the announcement of new 200% tariffs on Russian aluminum.  CBP’s guidance outlines new reporting requirements for all imports of aluminum and aluminum derivative products, regardless of the country of origin.

The new reporting requirements follow the issuance of Presidential Proclamation 10522.  Under Proclamation 10522, any…

On February 7, 2022, the United States and Japan issued a joint statement announcing a 232 tariff agreement allowing historically-based sustainable volumes of Japanese steel products to enter the U.S. market without tariffs.

An overview of the actions as provided by the Department of Commerce is provided below:

The United States will replace the existing…

On October 31, 2021, the Office of the United States Trade Representative (USTR) announced that the United States would be replacing the existing 25% tariff on EU steel and 10% tariff on EU aluminum under Section 232 with a tariff-rate quota (TRQ). As such, eligible products that are within the quota will be able to…

On June 15, 2021, the U.S. and EU announced a commitment to address steel and aluminum excess capacity issues including section 232 tariffs and retaliatory measures by the end of the year. This announcement follows the May 17th, 2021 statement from the European Commission Executive Vice President’s  outlining the EU’s decision to temporarily…

On May 17, 2021, European Commission Executive Vice President Valdis Dombrovskis announced that the European Union will temporarily suspend the increase of its rebalancing measures related to the Unites States’ Section 232 steel and aluminum tariffs. The tariffs, previously scheduled to go into effect on June 1, 2021, would increase duties on U.S. products…

On February 8, 2021, a WTO dispute resolution panel notified parties that it would delay it’s ruling on the United States’ Section 232 tariffs until the second half of 2021. The tariffs, which were imposed on the basis of national security, received complaints from China, India, Norway, Russia, Switzerland, Turkey, and the European Union. The…