Section 232 Tariffs

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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…

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…

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…

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…

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…

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…