Section 232 Steel Tariffs Changes on March 12

On February 10, 2025, President Trump signed Executive Order (EO), Adjusting Imports of Steel into The United States.

Effective March 12 at 12:01 am ET, all imports of certain steel articles and derivative steel articles shall be subject to the additional ad valorem tariffs under Section 232 at 25%. This EO reverts Section 232 on steel back to its original 2018 form with a few differences.

Over the past few years, several exemptions and product exclusions have been granted to goods of specific country of origins, to importers of specific products, and on specific Harmonized Tariff Schedule of the United States (HTSUS) numbers. All country of origin and general approved exclusions (GAEs) will be revoked. Importer-specific exclusions will continue to be available until their expiration.

The EO includes language that allows the addition of new steel derivative products and mentions steep monetary penalties in the case of misclassification that leads to non-payment of Section 232 duties.

What to Expect

More Details

A Federal Register notice will be published soon. It will contain additional details and confirm the information in the Executive Order.

Exclusions

Country of Origin Exemptions

Products of certain country of origins will no longer be exempt from the 25% duty. This includes origins that have been eligible for an absolute and tariff-rate quota.

• Argentina
• Australia
• Brazil
• Canada
• Japan
• Mexico
• South Korea
• EU member countries
• Ukraine
• United Kingdom

Importer-Specific Exclusions

• Authorization for the Secretary to grant relief for certain products is revoked.
• As of 11:59 pm ET on Feb 10, 2025, the Secretary shall not consider any product exclusion requests or renew any requests in effect.
• The product exclusion process will be rescinded.
• Granted product exclusions shall remain effective until their expiration date or until excluded product volume is imported, whichever occurs first.

General Approved Exclusions

All existing General Approved Exclusions shall be terminated as of March 12, 2025.

New for Derivative Steel Articles

• Section 232 duties shall not apply to derivative steel articles processed in another country from steel articles that were melted and poured in the U.S.
• Importers will need to provide any information necessary to identify the steel content used in the manufacture of steel derivative article imports.
• Within 90 days, the Secretary shall establish a process for including additional derivative steel articles.

Drawback

No drawback shall be available for these duties.

HTSUS Subject to Section 232

Steel Articles

(i) flat-rolled products provided for in headings 7208, 7209, 7210, 7211, 7212, 7225 or 7226;

(ii) bars and rods provided for in headings 7213, 7214, 7215, 7227, or 7228; angles, shapes and sections of 7216 (except subheadings 7216.61.00, 7216.69.00 or 7216.91.00); wire provided for in headings 7217 or 7229; sheet piling provided for in subheading 7301.10.00; rails provided for in subheading 7302.10; fish-plates and sole plates provided for in subheading 7302.40.00; and other products of iron or steel provided for in subheading 7302.90.00;

(iii) tubes, pipes and hollow profiles provided for in heading 7304 or 7306; tubes and pipes provided for in heading 7305;

(iv) ingots, other primary forms and semi-finished products provided for in heading 7206, 7207 or 7224; and

(v) products of stainless steel provided for in heading 7218, 7219, 7220, 7221, 7222 or 7223.

Derivative Steel Articles

(A) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in powder-actuated handtools, threaded (described in subheading 7317.00.30); and

(B) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505, 7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65)

(C) bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30); and

(D) body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).

We will continue to monitor this tariff action and provide updates as they become available.