On February 10, President Trump signed two proclamations adjusting the already-existing Section 232 tariffs on imports of steel and aluminum. He also directed U.S. Customs and Border Protection (CBP) to “dramatically increase” its enforcement efforts to prevent circumvention.

Increased tariff enforcement

The proclamations direct CBP to prioritize reviews of the classification of imported steel and aluminum products. If classification errors result in underpaid Section 232 tariffs, CBP:

  • Must impose the maximum penalty permitted by law.
  • May not consider evidence of any mitigating factors in its penalty determination.

Adjustments to steel and aluminum tariffs

Under the proclamations:

  • The previously granted exclusions for steel and derivative steel articles from Argentina, Australia, Brazil, Canada, the European Union, Japan, Mexico, South Korea, Ukraine, and the United Kingdom will be revoked, effective March 12, 2025 at 12:01 a.m. (ET). Imports of steel and derivative steel articles from these countries will then be subject to 25% ad valorem duties.
  • The previously granted exclusions for aluminum and derivative aluminum articles from Argentina, Australia, Canada, the European Union, Mexico, and the United Kingdom will be revoked, effective March 12 at 12:01 a.m. (ET).
  • The ad valorem tariff rate for aluminum and derivative aluminum articles will increase from 10% to 25%, effective March 12 at 12:01 a.m. (ET).
  • The Secretary of Commerce’s ability to consider or renew product exclusion requests is revoked, effective February 10. Granted product exclusions will remain in effect until they expire or the excluded product volume is imported.
  • The Secretary of Commerce must terminate all existing General Approval Exclusions, effective March 12.
  • The lists of derivative steel and aluminum products subject to Section 232 tariffs will be expanded by yet-to-be-published annexes to the proclamations. Tariffs on these derivatives will be suspended until the Secretary of Commerce gives public notice that adequate systems are in place to fully, efficiently, and expediently process and collect the tariffs.
  • Steel and aluminum products impacted by these proclamations that are admitted to foreign trade zones on or after March 12 must be admitted as “privileged foreign status” unless they are eligible for admission under “domestic status.”
  • Importers may not claim drawback on these newly imposed tariffs.
  • The Secretary of Commerce will establish a process within 90 days to include additional derivative steel and aluminum articles within the scope of the Section 232 tariffs. Domestic producers and related industry associations may request that derivative products be included within the tariffs’ scope. The Secretary of Commerce must then issue a determination within 60 days of the request.