President Trump Restores Section 232 Tariffs

On February 10, 2025, President Trump signed proclamations to reinstate the full 25% tariff on steel imports and increase tariffs on aluminum imports to 25%.[1] Section 232 of the Trade Expansion Act of 1962 affords the President with the authority to adjust imports being brought into the U.S. in quantities or under circumstances that threaten to impair national security. The President says the reinvigorated Section 232 tariffs “will support the program’s original objective of revitalizing the domestic steel and aluminum industries and achieving sustainable capacity utilization of at least 80%.” These tariffs will take effect on March 12, 2025.

The purpose of the tariffs is to enhance national security and end unfair trade practices and the global dumping of steel and aluminum. During Trump’s first term, a report found that steel import levels and excess production, particularly in China, were weakening the U.S. economy.[2] If domestic steel and aluminum production continues to decline, the President is concerned the U.S. may be unable to meet demand for national defense and critical infrastructure in a national emergency. Of additional relevance with the 25% tariffs on steel and aluminum is the fact that all Section 232 exclusions are terminated. Historically, importers could apply for exclusions for steel and aluminum products deemed unavailable from U.S. sources or critical to national security interests. The Department of Commerce will no longer accept new product exclusion requests. Granted specific product exclusions will remain in effect until their expiration date or until the excluded product volume is imported, whichever comes first. General approved exclusions (GAEs) will terminate on March 12, 2025. 

Additionally, all alternative agreements are terminated. Alternative agreements had provided certain countries with partial or total relief from Section 232 tariffs. This reform affects aluminum and steel imports from Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korea, the European Union, and the United Kingdom and steel imports from Ukraine. The President determined that imports from these countries threaten U.S. national security by inadvertently creating loopholes that are exploited by China and others with excess steel and aluminum capacity. Therefore, aluminum and steel products from these countries are subject to the additional tariff.

Further, the tariffs on steel and aluminum imports are expanded to include key downstream products, but the products affected have not yet been identified. The proclamations also create a new process at the Department of Commerce to expand the coverage of the tariffs. Producers or industry groups will be able to request the inclusion of additional products if they can demonstrate that increased imports of those products threaten national security. Once the Secretary receives a request, a determination will be issued within 60 days.  

Other provisions in the proclamations include:

• Customs and Border Protection is directed to prioritize investigating potential instances of tariff misclassification and assess monetary penalties in the maximum amount permitted by law.
• Aluminum and steel imports entering a U.S. foreign trade zone (“FTZ”) must enter with “foreign privileged status.”
• No duty drawbacks are available.
• Strict “melted and poured” standards will apply for imports of steel, aluminum, and derivative steel and aluminum products.

President Trump plans to monitor the implementation and effectiveness of these actions in addressing the U.S.’s national security needs and revisit the tariffs as needed. Companies that may be impacted by these tariffs should closely watch for any new developments or possible retaliatory tariffs and consider proactive strategies such as reviewing country of origin and considering available alternative supply routes. 

For additional inquiries, feel free to reach out to Brandon French at [email protected] or Olivia Van Pelt at [email protected] to discuss Section 232 tariffs in more detail.

[1] Adjusting Imports of Steel into The United States – The White House; Adjusting Imports of Aluminum into The United States – The White House

[2] Fact Sheet_ President Donald J. Trump Restores Section 232 Tariffs The White House.pdf