As Tariffs Loom, Steel and Aluminum Rules Remain in Flux with Lost Exclusions and Increased Duties

Mar. 11, 2025
By: David G. Forgue

Since at least February 10 importers have known that Section 232 duties were to be imposed on imports of steel from countries that had negotiated alternative arrangements to avoid these duties. For aluminum importers this knowledge goes back to February 11. However, with imposition of duties hours away, the details are still being clarified.

First, Commerce has notified at least some importers that product exclusions extended past their original deadlines as part of President Biden’s steel deal with Europe are being terminated. These “STX” exclusions were originally granted on the same terms as other 232 steel exclusions, generally with a showing that there was no, or insufficient, supply in the United States. The exclusions were then extended so that companies with such exclusions did not need to reapply annually. Because the original proclamation indicated that existing exclusions would be allowed to expire naturally, many importers believed that their STX exclusions were included in that group. Instead, Commerce has chosen to treat these STX exclusions as part of the quota arrangements that the proclamation ended.

Second, the morning of March 11 President Trump announced that steel imports from Canada would face an additional 25% duty beyond the 232 duties. The new 25% duties are apparently in retaliation for an energy surcharge imposed by Ontario on certain U.S. customers of Ontario electricity suppliers. The status of these additional duties is fluid and readers should be on the look out for legally binding material that raises these duties.

Finally, Customs reiterated that any existing steel or aluminum quotas would close at 4:30 on March 11 (local port time). This was previously announced, but Customs also issued a separate message reiterating the timing.

Do not hesitate to contact any attorney at Barnes, Richardson & Colburn, LLP if you have any questions regarding steel or aluminum tariffs.