W2C wishes to inform its clients who import goods into the United States about significant changes announced on February 10, 2025, regarding additional tariffs (aka surtaxes) on steel and aluminum products.

Amongst many others, the U.S. President has issued two specific proclamations that will affect importations of steel and aluminum products into the USA.

Proclamation - Adjusting Imports of Steel Into the United States

Proclamation - Adjusting Imports of Aluminum Into the United States

Fact Sheet: President Donald J. Trump Restores Section 232 Tariffs

Note: Please keep in mind that the implementation of additional tariffs on goods imported into the USA remains a fluid situation. The information below represents the most up-to-date details available as of February 24, 2025.

Main changes as outlined in the two proclamations

• The 25% tariff (per §232 of the Trade Expansion Act of 1962) on steel and steel derivative products will be extended to imports into the USA from ALL countries, including from Canada.
• The existing tariff (per §232 of the Trade Expansion Act of 1962) on aluminum and aluminum derivative products will be increased from 10% to 25% as well as extended to imports into the USA from ALL countries, including from Canada.
• While both proclamations contain language suggesting that these tariffs on derivative articles of steel or aluminum will not take effect until the Department of Commerce provides public notification that adequate systems are in place to fully, efficiently, and expediently process and collect associated tariff revenue, unless the tariffs are revoked or suspended, the Section 232 tariffs are scheduled to go into effect for all specified steel and aluminum products imported into the U.S. on or after 12:01 a.m. EDT on March 12, 2025. To view the list of aluminum and steel products presently targeted by the 25% Section 232 tariffs on steel and aluminum, click here.

For more details on steel and aluminum products targeted by these proclamations, please refer to Annex 1 in each of following Federal Register Notices:

FRN – Proclamation 10895 - Adjusting Imports of Aluminum Into the United States

FRN – Proclamation 10896 - Adjusting Imports of Steel Into the United States

• The alternative agreements that existed for imports of steel and aluminum goods from Argentina, Australia, Brazil, Canada, the European Union, Japan, Mexico, South Korea, Ukraine, and the United Kingdom are being terminated. Consequently, ALL specified goods of steel or aluminum, regardless of their country of origin, are now being targeted by these new tariff measures.

• Moreover, imports of specified derivative aluminum articles of origin Russia, as well as all imports of specified derivative aluminum articles, where any amount of primary aluminum used in the manufacture of the derivative aluminum articles is smelted in Russia, or the derivative aluminum articles are cast in Russia, shall be subject to the 200% tariff.

• The 25% Section 232 tariffs on steel and aluminum goods will apply in addition to any regular customs duties, anti-dumping or countervailing duties, Section 301 tariffs, as well as in addition to other CBP levies (e.g. MPF or HMF user fees), which may apply on the importation of the specified goods into the USA.

• Depending on the type of steel or aluminium product, the 25% Section 232 tariff will be assessed on the full entered value of the product, or for certain other products the tariff shall apply only to the steel or aluminum content of the derivative article.

  IMPORTANT: It is our present understanding that should the U.S. President go forward, for example on March 4, 2025, with the application of additional tariffs on ALL goods of origin from Canada (under the IEEPA – International Emergency Economic Powers Act) as he originally planned to do on February 1, 2025, with regard to specified steel or aluminum products of Canadian origin, the 25% Section 232 tariffs discussed herein would be calculated in addition to the 25% IEEPA tariffs. In other words, 50% supplementary tariffs (25% + 25%) if both IEEPA and Section 232 tariffs go into effect.

• Under the present proclamations, ALL quota agreements will be terminated, and any existing exclusion orders are also being terminated. That said, product exclusions that had previously been granted will remain in effect until their expiration date or until their exempted volume has been imported, whichever occurs first.

• The existing processes for U.S.-based importers to request exclusions from the additional tariffs on aluminum and steel products were terminated on February 10, 2025. *** Only steel products melted and poured in the U.S. or aluminum products smelted and cast in the U.S. will be exempted from these Section 232 tariffs.**

• No drawback shall be available with respect to the Section 232 tariffs imposed pursuant to these proclamations. In other words, if goods subject to the 25% tariffs are entered into the USA, even if reexported from the USA in same condition or after value-added processing, the 25% tariffs are not eligible to a duty-drawback refund.

Credit and risk considerations

In the event these new tariffs on goods imported into the United States do materialize, U.S.-licensed customs brokers may require that importer-clients pay U.S. duties and tariffs before the customs clearance of subject goods (i.e. before arrival of shipments at the U.S. first port of arrival). This requirement for pre-payment of duties and tariffs could result in significant delays and additional administrative costs.

To avoid these complications W2C strongly recommends that clients who act as importer of record into the USA, register ASAP with U.S. Customs and Border Protection (CBP) for the Automated Clearinghouse (ACH) payment option. ACH is a type of pre-authorized debit which allows importers to pay customs duties and other import tariffs electronically to CBP, thereby reducing the risk of clearance delays at the border and minimizing additional costs.

Registering for ACH is a simple process and can greatly facilitate the payment to CBP of high duty outlays for your U.S. customs transactions.

For updates on the evolving tariff situation or if you would like more information or assistance with your registration to the ACH payment option, please contact W2C.