National Security Tariffs on Steel and Aluminum Imports

On February 10 and 11, 2025, President Trump issued two Presidential Proclamations that impose 25% national security tariffs on imported articles of steel, derivative steel articles, aluminum articles, and derivative aluminum articles (collectively, “232 Tariffs”).¹ These actions aim “to protect America’s steel and aluminum industries, which have been harmed by unfair trade practices and global excess capacity.”² Applicable beginning on March 12, 2025, the Proclamations impose the tariffs by nullifying exemptions to various countries, reinstating and expanding steel and aluminum tariffs, and raising aluminum tariffs. 

Under the Steel Proclamation, the 232 Tariffs will cover steel articles imports under Harmonized Tariff Schedule US (HTSUS) subheading 9903.80.01.³ In addition, the Proclamation rescinds certain exemptions from 232 Tariffs on steel articles and derivative steel articles by Argentina, Australia, Brazil, Canada, the European Union member countries, Japan, Mexico, South Korea, and Ukraine. Of particular importance, the additional derivative steel articles covered by the Steel Proclamation shall be subject to the ad valorem duties proclaimed in Proclamation 9705 and Proclamation 9980, except for derivative steel articles processed in another country that are made from steel articles that were melted and poured in the United States.⁴  

The Aluminum Proclamation modifies Proclamation 9704 by increasing the ad valorem duty rate on covered imports of derivative aluminum articles from 10% to 25%. The tariff rate on imports of aluminum from Russia will be 200%. These rates of duty, which are in addition to any other duties, fees, exactions, and charges applicable to such imported derivative aluminum articles, shall apply to imports of derivative aluminum articles described in Annex I to the Aluminum Proclamation from all countries, except for derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States.⁵ 

Further, in an effort to bolster the effectiveness of the 232 Tariffs, the Steel Proclamation and Aluminum Proclamation eliminate the product exclusion processes that had previously been authorized under Proclamations 9704, 9705, and 9980. As a result, it appears that importers will find it more difficult to bypass the 232 Tariffs. 

While these 232 Tariffs are set to establish an important national security protection for U.S. steel and aluminum producers, it is important to note that this initial trade action also provides opportunity for producers to seek inclusion of additional derivative steel and derivative aluminum articles. Within 90 days from the date of the proclamations, the U.S. Department of Commerce (Commerce) is required to establish a process for certain parties to request including additional articles within the scope of 25% duties proclaimed in Proclamations 9704, 9705, and 9980. Within 60 days of receiving any such request, Commerce will be required to issue a determination on whether or not to include the article. This is a critical opportunity for domestic producers of steel articles, derivative steel articles, aluminum articles, derivative aluminum articles, or industry associations representing such producers to assess whether products would benefit from the imposition of 232 Tariffs.   

Buchanan has a team of international trade and national security attorneys, and government relations professionals ready to help U.S. manufacturers with U.S. trade remedy laws and trade policy. U.S. AD/CVD tariff laws are one of the only available tools to reestablish an even playing field for American companies and avoid lost sales and profits. Our eBook, Protecting Domestic Producers: A Guide to Antidumping and Countervailing Investigations, shares details on how diverse domestic industries can take advantage of these laws – antidumping and countervailing duty investigations – to combat unfair foreign competition and receive adequate remedies and protections. Our dedicated team has decades of experience supporting clients across a range of industries – ranging from steel, chemical, rubber, mining, and agricultural products – to ensure that the U.S. market is operating under fair and equal conditions.