Client Advisory: Revisions to Section 232 Steel and Aluminum Tariff Exclusions Process

On May 17th, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a final rule revising the Section 232 exclusions process for both steel and aluminum imports into the United States.

These revisions are effective July 01, 2024, and intend to improve the structure under which exclusions from the tariffs on steel and aluminum can be requested, warranting a more fair and evident process.

The revisions remove the following twelve General Approved Exclusions (GAEs) – 6 for steel and 6 for aluminum:

Removing these GAEs supports the effectiveness of the Section 232 tariffs and therefore U.S. national security.

The GAEs were initially established to streamline the exclusions process for products consistently found not to be produced in reasonably sufficient quantity or quality within the United States or for products which the Secretary of Commerce deems should be excluded based upon specific national security considerations.

The steel and aluminum articles listed within the 12 GAEs above will revert to the duties and treatment previously established under Presidential Proclamations 9704 and 9705 as well as later Proclamations.

It must be noted that should analysis of these GAEs change in the future, BIS may reissue these GAEs in whole or in part in following rules.

In accordance with Presidential Proclamations 9704 and 9705: all imports of aluminum articles shall be subject to an additional 10% ad valorem, or value-based tax, rate of duty and imports of steel articles shall be subject to an additional 25% ad valorem rate of duty – both articles with respect to goods entered or withdrawn from warehouse for consumption.

These rates of duty, which are in addition to any other duties, fees, exactions, and charges applicable to such imported aluminum or steel articles, shall apply to imports of aluminum and steel articles from all countries except Canada and Mexico.

What does it mean to You?

U.S. Importers please be aware of the situation and prepare for the changes as early as possible.

For any questions reach out to Crane Worldwide's Global Trade Compliance Team: Globaltradecompliance@craneww.com