Changes to Steel and Aluminum Duties are in the Wind

Oct. 9, 2025
By: David G. Forgue

Any importer of steel or aluminum, or articles made of steel or aluminum (and for an unlucky few, steel and aluminum) knows that in 2025 change is the only constant. With that in mind, it appears that we are about to get more of the same (change). First, Commerce released the requests for inclusion for steel and aluminum 232. Then the EU and Canada both took steps to more closely align with U.S. steel policy.

With respect to the inclusions list, there are fewer requests than the 400 plus in the first round of inclusions, but some that may be more surprising (we have a list of tariff numbers if you email me). It’s important that importers not be caught unaware if 232 duties are to be imposed. For instance, tariff provisions covering a range of foods were requested. These are diverse as sweet biscuits, coffee, instant coffee, tuna, dog and cat food, juice, mineral water, soups, ham, cashews, peaches, vegetables, fruits, and others. However, requesters also asked for duties on wheel chairs, bicycle parts, pump parts, refrigeration parts, and a range of other steel and aluminum articles. Comments can be filed at regulations.gov until October 21 and we do not expect that deadline to be impacted by the government shutdown.

At the same time, both the EU and Canada are taking active steps to align with the United States on steel importing rules (as well as aluminum for Canada). This makes a certain amount of sense, since China alone produces over half the world’s steel and exports displaced from American markets are very likely to flood Canadian and EU markets. Thus, the EU Commission is seeking to impose 50% duties on steel imports above a quota level to be set by the EU. Not only does this appear intended to set the level of steel imports at 2013 levels (without imposition of the higher duty), but also to convince the Trump administration to give European steel concessions with in the U.S. steel regime. Until ended by President Trump European steel operated with a tariff-rate quota into the United States.

At the same time, Canada has established a steel tariff-rate quota system. Initially only applied to countries not having a free trade agreement with Canada, the system has since been expanded. While Canada’s tariff-rate quota system is surely intended to protect Canadian steel manufacturers, it is also a talking point between the Canadian and United States governments as they seek to come to an agreement in steel and aluminum imports.

The EU and Canadian actions come in the wake of broader trade measures taken by Mexico to regulate its trade. For countries without a free trade agreement with Mexico (something China does not have) Mexico imposed 50% or higher duties across a broad range of imports. The stated aim was to bolster manufacturing in Mexico.

What does this all mean for manufacturers, users, and purchasers of articles of steel or aluminum? It means change remains the only constant. Supply chains are distorted by the desire to avoid higher duties and mitigate rising costs. Now that the EU and North America are all raising tariffs it’s more important that ever to have access to expertise in the area. Contact any attorney at Barnes, Richardson & Colburn, LLP for such expertise.