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02/21/2025
Steel & Aluminum Tariff Increases Confirmed for March 12, 2025
Check out this week's Customs Corner to read about increases to U.S. Steel and Aluminum Tariffs, Reciprocal Trade and Tariffs, and more.
Trade and Customs Updates
1) Update: Increases to U.S. Steel and Aluminum Tariffs – Effective March 12, 2025 – Published
GEODIS wants to keep you informed about significant changes to U.S. Section 232 tariffs on steel and aluminum imports, which will impact global trade operations beginning March 12, 2025.
KEY TAKEAWAYS:
- All existing country exemptions for Section 232 steel and aluminum tariffs will be eliminated
- Steel and aluminum tariffs will be set at 25% for imports into the U.S.
- No new tariff exclusions will be granted; existing exclusions are valid until expiration or volume completion, whichever occurs first
- New derivative products will be subject to tariffs (list is available under Annex I of the Federal Register)
- Additional documentation requirements for U.S.-processed materials
DETAILED INFORMATION:
Steel Tariff Changes:
- Effective March 12, 2025, existing alternative agreements will be terminated for: Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, the U.K., and Ukraine
- The Section 232 steel tariff exclusion process is ending:
- No new exclusions will be considered or renewed
- Existing exclusions remain valid until expiration or volume completion, whichever occurs first.
- All general product exclusions terminate March 12
- New 25% tariff on additional steel derivative products (implementation pending Commerce Department systems readiness)
- For derivatives outside Chapter 73, tariffs will apply only to aluminum content
- Exemption available for derivatives processed from U.S.-melted and poured steel, with required CBP documentation
- The Federal Register has been published which includes the steel derivative HTS under Annex I
- Documentation will be required to support steel content used in the manufacture of derivative goods
- CBP to prioritize reviews of the classification of imported steel articles and derivative steel articles, misclassification may result in penalties
Aluminum Tariff Changes:
- Tariff rate increases to 25% on March 12, 2025, for all countries except Russia
- Effective March 12, 2025, exemptions and quota agreements will be terminated for: Argentina, Australia, Canada, Mexico, the EU, and the U.K.
- The Section 232 aluminum tariff exclusion process is ending:
- No new exclusions will be considered or renewed
- Existing exclusions remain valid until expiration or volume completion, whichever occurs first
- All general product exclusions terminate March 12
- New 25% tariff on additional aluminum derivative products (implementation pending Commerce Department systems readiness)
- Derivative articles in Annex I from Russia where any amount to of primary* aluminum is smelted or cast in Russia is subject to 200% duties.
- *Primary aluminum is defined as new aluminum metal that is produced from alumina (or aluminum oxide) by the electrolytic Hall-Heroult process.
- For derivatives outside Chapter 76, tariffs will apply only to aluminum content
- Exemption available for derivatives made from U.S.-smelted and cast aluminum, with required CBP documentation
- The Federal Register has been published which includes the aluminum derivative HTS under Annex I
- Documentation will be required to support aluminum content used in the manufacture of derivative goods
- CBP to prioritize reviews of the classification of imported aluminum articles and derivative aluminum articles, misclassification may result in penalties
Additional Provisions:
- Producers and trade associations may request additions to the derivative products list for both steel and aluminum
- Implementation of certain derivative tariffs pending Commerce Department system updates
- No new exclusions will be granted or renewed for either steel or aluminum
References: Federal Register, Federal Register
2) Reciprocal Trade and Tariffs
President Trump issued a Memorandum dated February 13, 2025 outlining his plan for reciprocal tariffs.
The Memorandum confirms that following the submission of agency reports mandated under the America First Trade Policy Memorandum, the Secretary of Commerce and the United States Trade Representative (USTR), in consultation with key government officials, will take all necessary steps to investigate the economic and trade impact of non-reciprocal trade agreements adopted by U.S. trading partners. These officials include the Secretary of the Treasury, the Secretary of Homeland Security, the Assistant to the President for Economic Policy, the Senior Counselor to the President for Trade and Manufacturing, and other relevant executive department heads as deemed necessary by the Secretary of Commerce and the USTR.
Upon the completion of these investigative actions, the Secretary of Commerce and the USTR will present a comprehensive report to the President. This report will outline recommended measures to address and rectify any identified trade imbalances and propose strategies for securing reciprocal trade relations with each partner nation.
Additionally, within 180 days of the memorandum's issuance (August 18, 2025), the Director of the Office of Management and Budget (OMB) will conduct a thorough assessment of the fiscal implications on the federal government. This assessment will also evaluate the impact of any associated information collection requirements on the public. A written report detailing these findings will then be submitted to the President for further review and consideration.
To ensure effective implementation of the memorandum’s objectives, the following steps will be undertaken:
- Data Collection and Analysis:
- A detailed review of existing trade agreements and their economic impact on U.S. industries and jobs.
- Examination of trade deficits and surpluses with key partners to identify any unfair trade advantages.
- Stakeholder Consultations:
- Engagement with industry representatives, labor unions, and economic experts to gather insights on trade-related harm.
- Collaboration with state and local governments to understand regional trade impacts.
- Policy Formulation and Recommendations:
- Development of policy measures to counteract non-reciprocal trade practices, including potential tariff adjustments, renegotiation of agreements, and enforcement actions.
- Identification of legal avenues for implementing proposed remedies, ensuring compliance with international trade laws.
- Monitoring and Enforcement:
- Establishment of mechanisms to continuously track the effectiveness of new trade policies.
- Regular reporting and assessment to ensure alignment with the America First Trade Policy objectives.
3) Updates to the ACE Protest Module for CAATSA Exception Reviews
On January 21, 2025, U.S. Customs and Border Protection (CBP) deployed updates to the Automated Commercial Environment (ACE) Protest Module, introducing a new secondary issue for Countering America’s Adversaries Through Sanctions Act (CAATSA) exception reviews. These updates enhance the ability of protest filers to contest exclusion decisions related to CAATSA compliance.
On January 21, 2025, U.S. Customs and Border Protection (CBP) deployed updates to the ACE Protest Module to include a new secondary issue for Countering America’s Adversaries Through Sanction Act (CAATSA) exception reviews.
Protest filers will notice modifications to the ACE Protest user interface (UI). Specifically, those protesting a Notice of Exclusion related to CAATSA now have a streamlined method to contest a CBP exclusion decision within the ACE Protest Module.
To request a CAATSA exception review, protest filers should follow these steps:
- On the protest creation screen, select “Merchandise Excluded from Entry” under the “Issue” field.
- Choose “CAATSA Exception Review” as the “Secondary Issue.”
- Submit the protest, which will then be routed to the applicable Center of Excellence and Expertise (Center) or the Port of San Juan for thorough review.
Protest filers should select “CAATSA Exception Review” in the following scenarios:
- When importers seek an exception to rebut CAATSA’s rebuttable presumption that their merchandise is made with forced labor.
- When requesting an exception to challenge the presumption that the excluded goods are produced using forced labor.
To successfully rebut the presumption, importers must provide clear and convincing evidence demonstrating that the detained goods were not produced with forced labor by North Korean nationals or citizens, as outlined in 22 U.S.C. 9241a(b). Documentation and supporting materials should be comprehensive to meet CBP’s evidentiary standards for exemption consideration.
These updates aim to improve efficiency and transparency in the protest process for importers impacted by CAATSA regulations, ensuring compliance with U.S. trade laws while providing a clear path for exception reviews.
Reference: CSMS # 64151118, Federal Register
4) Legacy ACE Platform to Retire
Legacy ACE Platform Retires February 22, 2025.
On February 22, 2025, U.S. Customs and Border Protection (CBP) will transition Automated Commercial Environment Secure Data Portal (ACE Portal) account user access management to the updated ACE Portal. After this deployment, the legacy ACE Portal will be retired.
Reference: CSMS # 64152482
EVENT: Navigating the Latest U.S. Trade & Tariff Policies: What We Know & What Remains Uncertain
February 27, 2:00 – 3:00 PM CT
Join us for another in-depth webinar covering the latest updates on U.S. trade policies and tariffs. Don’t miss your chance to gain actionable insights from industry experts!
EVENT: CBP's Trade Facilitation and Cargo Security Summit
May 6 - 8, 2025 | Hilton New Orleans Riverside, Two Poydras St, New Orleans, LA 70130
This event will be hosted in person and webcasted. Event and registration details will be available soon and posted to the TFCS Summit web page. Click here for more information.
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