Section 232 Steel and Aluminum Tariffs Rise, Change, and Maybe Expand

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Jun. 9, 2025
By: Hannah B. Kreinik

On June 6, the Trump Administration published a Presidential Proclamation increasing steel and aluminum duties under Section 232 from 25% to 50% starting on June 4th (please see our articles covering the original steel and aluminum duties back in March). The Federal Register notice can be found here while the CBP CSMS guidance updates (as of June 7) can be found here, here, and here.

The proclamation and CSMS guidance do a few things. First, with the sole exception of steel from the U.K., the proclamation increased the duties for goods entered for consumption or withdrawn from a warehouse starting at 12:01 a.m. Eastern time on June 4, 2025.

Second, the proclamation clarifies that more products are eligible for reporting only the steel or aluminum value of the import. However, it also removes the exemption from reciprocal duties from the non-steel or aluminum portion. Thus, some importers will pay 50% for a portion of their imports and the reciprocal rate for the remainder. This is different (for those products) from the previous requirement to pay 25% on the full value of the goods.

Third, the proclamation discusses Annexes I-III.

Fourth, with respect to U.K. imports, this proclamation carved out an exception for the U.S.-U.K. Economic Prosperity Deal (EPD) reached on May 8, 2025. Steel and aluminum products from the U.K. will remain at 25% until July 9, 2025. At that time, the Secretary of Commerce may adjust the duty rate, create import quotas based on the terms of the EPD, or move the U.K. duty rate up to 50% if the U.K. is not in compliance with the agreement. Per Federal Register notice, applicable UK steel and aluminum products should use 9903.81.94-97 and 99 (steel) and 9903.85.12,13, 14, and 15 (aluminum) respectively when entering goods.

Finally, the proclamation mirrors language found in other proclamations in other respects. No duty drawback is permitted, provisions are provided for goods entered into FTZs under privileged foreign and domestic status, CBP may take appropriate actions to administer the tariffs, and the Secretary of Commerce (in consultation with the International Trade Commission) can modify the HTSUS as needed through the Federal Register. Per previous steel and aluminum orders, there is an exception for goods with steel that was melted and poured in the United States and aluminum articles smelt and cast in the United States. Reporting requirements remain for the countries of melt and pour for steel and the countries and secondary countries of smelt and cast for aluminum products. The 200% duty on Russian aluminum products and derivative products remains intact. Active Section 232 exclusions remain in effect until their expiration and no new exclusions are permitted.

Barnes, Richardson & Colburn attorneys are ready to rise to the occasion and answer your burning questions on Section 232 duties.