Section 232 Steel and Aluminum Tariffs: What Importers Need to Know for 2025

As of March 12, 2025, the United States has implemented expanded Section 232 tariffs, imposing a 25% duty on imported steel and aluminum products. These tariffs represent a significant update to U.S. trade policy and will affect a broad range of industries relying on these materials.

Overview of the New Tariffs

The Section 232 tariffs apply a 25% duty rate on:

• Primary steel articles from all countries
• Primary aluminum articles from all countries
• Derivative steel and aluminum products
• Products processed in foreign trade zones with privileged foreign status

Key Points for Importers

Steel Products Affected

The tariffs cover a wide range of steel products including:

• Flat-rolled products (headings 7208-7212, 7225-7226)
• Bars and rods (headings 7213-7215, 7227-7228)
• Tubes, pipes, and hollow profiles (headings 7304-7306)
• Ingots and semi-finished products (headings 7206, 7207, 7224)
• Stainless steel products (headings 7218-7223)

Aluminum Products Affected

The aluminum tariffs impact:

• Unwrought aluminum (heading 7601)
• Bars, rods, and profiles (heading 7604)
• Wire (heading 7605)
• Plates, sheets, and strip (heading 7606)
• Foil (heading 7607)
• Tubes, pipes, and fittings (headings 7608-7609)
• Castings and forgings (subheading 7616.99.51)

Exceptions and Special Cases

1. U.S. Content Exception: Products processed from steel melted and poured in the USA or aluminum smelted and cast in the USA qualify for zero duty under specific HTS numbers (99038192 for steel, 99038509 for aluminum).
2. Russian Products: Russian aluminum and aluminum derivative articles face a substantially higher 200% duty rate (rather than 25%), effective since April 10, 2024.
3. Derivative Products: For certain derivative products, the 25% duty applies only to the value of the steel or aluminum content, not the entire product value.

Commercial Invoice Requirements

To ensure compliance with these regulations, importers must:

1. Declare Material Content: Clearly identify products classified under Chapters 72, 73, and 76 of the HTSUS that are subject to the 25% duty.
2. Report Weight: Report the quantity of aluminum and/or steel content in kilograms (kg), in addition to standard units specified in Chapters 1-97.
3. Specify Value Content: For derivative articles, commercial invoices must clearly indicate the value attributable to the aluminum and/or steel content.
4. Identify Country of Origin: Clearly state the country of origin for all imported goods.

Best Practices for Compliance

• Work closely with suppliers to obtain mill certificates verifying the composition and origin of steel and aluminum content in imported goods.
• Ensure commercial invoices contain complete information about material content, weight, and origin.
• Consider consulting with a customs broker or trade compliance specialist to navigate these complex regulations.
• For products with U.S.-melted steel or U.S.-smelted aluminum content, maintain proper documentation to qualify for the zero-duty exception.

These tariffs will significantly impact supply chains and pricing strategies for manufacturers and importers. Businesses should assess their exposure and consider alternatives such as sourcing from domestic suppliers or pursuing product exclusions where available.