The Bureau of Industry and Security (BIS) announced via Federal Register Notice the opening of the window to submit requests to include additional derivative products under the Section 232 steel and aluminum tariffs. The window opened on September 15, 2025 and is set to close on September 29, 2025, at 11:59 PM (EST). Requests are
Section 232 Tariffs
BIS Adds to Section 232 Steel, Aluminum Derivatives Lists
Posted in Section 232 Tariffs
The Bureau of Industry and Security (BIS) will include multiple additional items as steel and aluminum derivative products, which will be subject to the Section 232 measures on their steel and aluminum content.
The BIS’s notice will be published in the Federal Register on August 19, 2025, with the effect of the measure for the…
Steel Tariffs Doubled: How the Hike Could Reshape Construction Projects at Home and Abroad
To date the Trump Administration has issued multiple proclamations imposing varying rates of import duties on steel and aluminum and certain derivatives, including construction materials. These measures have added volatility and financial pressures to the construction sector both in the United States and abroad. Most recently, on June 3, 2025, President Donald Trump issued a…
White House Updates Section 232 Tariffs on Steel, Aluminum
On February 10, 2025, the White House released an executive order (“EO” or “Order”) titled “Adjusting Imports of Steel into the United States” that reinstates a 25% tariff on imports of steel and steel derivative products into the United States. The administration has also previewed a parallel executive order on aluminum and aluminum derivative product…
Trump Sets Stage for Future Tariffs and Trade Actions
On his first day in office, President Trump rolled out a sprawling set of directives to the heads of numerous government agencies charged with shaping U.S. trade policy. While stopping short of enacting new tariffs, the Presidential Memorandum defining an “America First Trade Policy” lays the investigative groundwork for potentially sweeping changes to tariffs and…
Goods Subject to Tariffs May Lose 321 De Minimis Treatment in Proposed Rulemaking
By John Brew, Maria Vanikiotis & Ivy Xun on
On January 21, 2025, U.S. Customs and Border Protection (CBP) published a notice of proposed rulemaking that would make goods subject to tariffs under Sections 232, 201, and 301 ineligible for the de minimis duty exemption under the Section 321 Program, which allows imported shipments not exceeding $800 to enter the United States duty-free. To…
Section 232: History and the Exclusion Process
By Daniel Cannistra & Jasmine Masri on
Posted in Section 232 Tariffs
Introduction
Section 232 of the Trade Expansion Act of 1962 serves as a critical U.S. trade policy tool designed to safeguard national security by regulating imports. The provision grants the President the authority to impose tariffs or other trade restrictions on imports that threaten national security. The underlying rationale is that certain imports could undermine…
New Section 232 Exclusion Proposed Rules Will Force Additional Burden of Proof on Importers and Domestic Producers
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…
GAO Report on Section 232 Exclusions Signals Increased Enforcement for Steel and Aluminum Importers
By John Brew on
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…
CBP Issues Guidance Requiring Reporting of Smelt and Cast Country of Origin for Aluminum Products to Enforce 200% Tariff on Russian Aluminum
By John Brew, Weronika Bukowski & Emily Devereaux on
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…