Section 232 Updates

UPDATE July 31st, 2025

Beginning August 2, 2025, a 50% tariff will apply to semi-finished copper products such as:

• Pipes
• Cables
• Electrical conductors

Does not apply to minerals, concentrates, cathodes, or scrap. Publication of the annex with specific tariff items is expected. No duty drawback is permitted. 

The Department of Commerce may expand the scope of the tariff and evaluate gradual increases through 2027–2029. We are monitoring its specific application by tariff item.

For more information, please see the White House Fact Sheet on Copper Tariffs

UPDATE July 1st, 2025

Steel and Aluminum Frequently Asked Questions (FAQ)

On June 30, US Customs provided an update for Frequently Asked Questions (FAQ) regarding Aluminum and Steel tariffs. The FAQ provides clarifying points to many questions collectively presented to the Trade community.

UPDATE June 25th, 2025

Section 232 Aluminum and Smelt Reporting

On June 13, 2025, U.S. Customs and Border Protection (CBP) issued a Cargo Systems Messaging Service (CSMS) # 65340246 on how to report the country of smelt and cast on Section 232 aluminum products. Effective June 28, 2025, if the country of smelt and/or cast is unknown, the importer is to report "UN" (unknown) as the country code. In these cases, a 200% ad valorem tariff will be assessed. CSMS # 65340246 - GUIDANCE: Section 232 Aluminum Import Instructions for Reporting Unknown for the Country of Smelt and Cast.

UPDATE June 24th, 2025

Additional Steel Derivative Products

On June 16, 2025, the Bureau of Industry and Security (BIS) published a notice in the Federal Register updating Annex 1 under Section 232 to include additional steel derivative products subject to tariffs. This action was taken pursuant to Presidential Proclamation 10947 issued on June 3, 2025, which adjusted tariffs on aluminum and steel imports.

Newly Added Products (Effective June 23, 2025):

The following items were added to the list of steel derivative products subject to the 25% ad valorem tariff:

• Combined refrigerator-freezers (HTSUS 8418.10.00)
• Small and large dryers (HTSUS 8451.21.00 and 8451.29.00)
• Washing machines (HTSUS 8450.11.00 and 8450.20.00)
• Dishwashers (HTSUS 8422.11.00)
• Chest and upright freezers (HTSUS 8418.30.00 and 8418.40.00)
• Cooking stoves, ranges, and ovens (HTSUS 8516.60.40)
• Food waste disposals (HTSUS 8509.80.20)

These products are now subject to tariffs based on the value of the steel content in each item

Full notice and Annex in the Federal Register PDF here

UPDATE June 5th, 2025

CBP Updated Guidance on Tariff Stacking

CBP recently issued updated guidance on the 'stacking' of different tariffs on top of one another. The full memo can be found here.

Effective June 4, for imported goods that are subject to more of the tariffs listed below, duties are applied in the following order based on these key rules:

Section 232 Auto/Auto Parts:

• If the part or vehicle is covered under the 232 automotive or parts tariff, the item is exempt from the following tariffs: 232 Aluminum, 232 Steel, and IEEPA Canada/Mexico.
• However, auto parts that qualify under USMCA are not subject to 232 Auto/Auto Parts or IEEPA tariffs. 

Section 232 Aluminum and Steel: 

• If the automotive/auto parts tariff does not apply, determine if the article is subject to aluminum and/or steel tariffs.
• For derivative products, duties are assessed on the value of each metal that's included in the product. 
• If applicable, the item is not subject to IEEPA Canada and Mexico tariffs. 
• Russia Note: Imports with aluminum, either smelted or cast in Russia, face a 200% Section 232 duty. 

IEEPA Canada and Mexico: 

• These tariffs only apply if the auto/auto parts, aluminum, and steel tariffs do not. 
• USMCA-qualified articles are exempt from IEEPA tariffs.

CBP Updated Guidance on Steel & Aluminum Imports 

• As of June 4, 2025, products classified in Ch. 73 (Articles of iron or steel) or 76 (Articles of aluminum) will be assessed the 50% duty only on the steel/aluminum content of that product. Previously, the tariff was asssesed on the full value of the imported product.
• CBP also updated additional guidance and updated Chapter 99 subheadings for Section 232 steel and aluminum imports:
  • Aluminum: view here. 
  • Steel: view here. 

UPDATE February 10th, 2025

On Feb. 10, the President issued Proclamation 10896 on Adjusting Imports of Steel into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), imposing 25 percent ad valorem tariffs on certain imports of steel articles and derivative steel articles from all countries. This is effective March 12.

For your reference:

• 90 FR 9817 and
• 90 FR 11249.

Retaliatory Tariffs on Section 232

• In response to the US imposing 25% additional duties to steel and aluminium. It has been announced by the European Commission that retaliatory duties against US imports to the tune of Euro.26 billion which will be imposed over two phases. The first phase will take effect from April 1, 2025 with the final imposition on April 13, 2025. A two week consultation will now take place with stakeholders to conclude on March 26 and then followed by the Commission’s proposal. Here is the European Commission’s statement. 

President Trump imposed a 25% tariff on all steel and aluminum imports into USA 

The White House just released two Executive Orders with respect to imposing 25% duty on all steel and aluminum derivative articles imports into USA, effective from March 12th, 2025.

The Executive Order is a modification of the original Section 232 duties on steel and aluminum derivative articles, NOT a new action. It means effectively a 25% tariff for steel and aluminum from all countries.

No Exemptions: All Section 232 previous exemption countries: Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korea, the European Union, Ukraine, and the United Kingdom will be void, and the steel and aluminum from these countries shall be subject to the additional 25% duty.

No Drawback:  There will be no drawback allowed against these duties.

Quotas Provisions: In lieu of tariffs for Argentina, Australia, Brazil, Canada, Mexico, Korea, EU, Japan, UK, and Ukraine are canceled as of March 12, 2025.

The Section 232 product exclusion process is terminated, effective immediately. As of the date of the proclamation (February 10, 2025), the Secretary cannot consider any product exclusion requests or renew any product exclusion requests currently in effect. Product exclusions already granted will remain in effect until their expiration date or until the excluded product volume is imported, whichever occurs first. The Secretary will terminate any General Approved Exclusions (GAEs) as of March 12, 2025.

Within 90 days, the Secretary will establish a process for U.S. producers or industry associations to ask that additional steel and aluminum derivative articles be put on the list of products subject to duties. The Secretary will then have 60 days to decide whether to approve the request.

All steel and aluminum derivative articles will have to be entered to Foreign Trade Zone in privileged foreign status beginning March 12, 2025, unless they qualify for domestic status.

The provisions on Russian steel and aluminum derivative articles from steel and aluminum melted or cast in Russia remain the same (i.e., 200% duty).

What does this mean to an Importer/Exporter? 

Importers should remain vigilant in assessing what impact an Executive Order, new regulation, new sanction, or any federal change may have on your global supply chain.

Keep informed with Crane Worldwide's Trade Advisory Notices, or email Crane Worldwide’s Global Trade Compliance team for any questions: globaltradecompliance@craneww.com