President Trump Expands Section 232 Tariffs on Steel and Aluminum

On February 10, 2025, President Donald Trump issued two proclamations, Adjusting Imports of Steel into the United States and Adjusting Imports of Aluminum into the United States pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (“Section 232”).¹ The corresponding Fact Sheet elaborates that these proclamations “close existing loopholes and exemptions to restore a true 25% tariff on steel and elevate the tariff to 25% on Aluminum.” Additional background on the Section 232 tariffs is provided in our August 2024 newsletter.

The new Proclamation on Steel outlines the following:  

1. The Secretary of Commerce informed the President that the initial 25% ad valorem tariff “has been an effective means of reducing imports, encouraging investment and expansion of production by domestic steel producers, and mitigating the threatened impairment of U.S. national security.”
2. The Secretary also informed the President that “imports of steel articles from certain countries exempted from the tariff [i.e., Argentina, Australia, Brazil, Canada, Mexico, South Korea, the European Union, Japan, the United Kingdom, and Ukraine] or subject to alternative agreements have increased significantly, while excess capacity in the global steel industry has begun to increase again in recent years.” Accordingly, as of March 12, 2025, “all imports of steel articles and derivative products” from these countries are subject to a 25% ad valorem tariff with respect to steel articles and derivative steel articles.
3. A surge of “exports of steel from the People’s Republic of China [(the “PRC”)]” that have effectively “displac[ed] production in other countries and forc[ed] them to export greater volumes of steel articles and derivative steel articles to the United States.”
4. Significant increases in imports of steel goods from Canada and Mexico, “including [in] Mexico’s imports from China, support a conclusion that there is transshipment or further processing of steel mill articles from countries that remain subject to the additional ad valorem tariff.”
5. As US “capacity utilization rates [are] persistently lower than the 80 percent target level highlighted in the Secretary’s report,” the President has adjusted the 25% ad valorem tariff to also apply to additional steel derivatives, set out in Annex I ² to the Proclamation, “except for derivative steel articles processed in another country from steel articles that were melted and poured in the United States.”

The new Proclamation on Aluminum outlines the following: 

1. The Secretary of Commerce informed the President that, despite the 10% ad valorem tariff on aluminum, “aluminum imports into the United States have continued at unacceptable levels as the global aluminum excess capacity crisis continues” and the 10% ad valorem tariff “is not high enough to address the threatened impairment to our national security posed by aluminum imports.”
2. The Secretary also informed the President that “global primary aluminum capacity has continued to increase, fueled by expansions in the [PRC] and South America, which is seen in rising aluminum imports that continue to” influence domestic prices. The Secretary noted that “[t]here has also been a significant increase in Chinese investment in Mexico, driven by massive Chinese government subsidies and the continued ability to exploit loopholes in U.S. trade policy.”
3. The Secretary also informed the President that “imports of aluminum articles from countries that are excluded from the tariff regime,” including Argentina, Australia, Canada, Mexico,³ the European Union, and the United Kingdom, “have remained significantly elevated at levels that once again threaten to import the national security of the United States.” Accordingly, the President found it “necessary to terminate” agreements with these countries for “all imports of aluminum articles and derivative aluminum articles.”⁴
4. Imports of derivative aluminum products have also “increased significantly” and have “erod[ed] the domestic industry’s customer base and result[ed] in depressed demand for aluminum articles produced in the United States.”
5. In line with the findings above, the President found it “necessary and appropriate” to adjust the 10% ad valorem tariff on aluminum articles to 25% “to remove the threatened impairment of the national security of the United States.” The President also applied the 25%⁵ ad valorem tariff to additional aluminum derivatives, set out in Annex I to the Proclamation.

Both Proclamations terminate the Section 232 exclusion process. As of February 10, 2025, at 11:59 p.m. EST, the Secretary of Commerce is neither considering new product exclusions nor renewing existing product exclusions. Commerce’s Bureau of Industry and Security explained that those exclusions that were already granted remain in effect until their expiration date or until their excluded volume is exhausted.
The above changes apply to products that are entered for consumption, or withdrawn from warehouse for consumption, at or after 12:01 a.m. EST on March 12.

Tariffs remain dynamic under the Trump Administration. Interested parties in tariffs and/or imports of steel and aluminum into the United States should continue to monitor updates from the administration.

¹ Section 232 allows the President to impose import restrictions based on an investigation and affirmative determination by the Secretary of Commerce that certain imports threaten to impair US national security.

² For any derivative steel article identified in Annex I that is not in Chapter 73 of the HTSUS, the additional ad valorem duty applies only to the steel content of the derivative steel article.

³ The President also noted that “Mexican producers are commingling primary aluminum from China and the Russian Federation (Russia) with primary aluminum from other countries to produce downstream aluminum articles.” 

⁴ All imports of derivative aluminum articles specified in Annex I to the Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of the derivative aluminum articles is smelted in Russia, or the derivative aluminum articles are cast in Russia, are subject to the 200% ad valorem rate of duty established in Proclamation 10522.

⁵ For any derivative aluminum article identified in Annex I that is not in Chapter 76 of the HTSUS, the additional ad valorem duty shall apply only to the aluminum content of the derivative article.