New U.S. Tariffs on Steel
and Aluminum Take Shape

March 12, 2018

On Thursday, March 8, President Trump issued two Presidential Proclamations announcing the imposition of special Section 232 duties on certain steel and aluminum products of 25 and 10 percent, respectively.  These duties are in addition to any other general or special (antidumping or countervailing) duty that may apply.

The Presidential Proclamation on Adjusting Imports of Steel into the United States can be accessed here.

The Presidential Proclamation on Adjusting Imports of Aluminum into the United States, can be here.

The proclamations provide the following important details:

  • Absent any intervention, the special duties will go into effect for designated goods entered for consumption or after March 23, 2018.
  • The tariffs affect designated steel and aluminum products from all countries except Canada and Mexico.
  • Canada and Mexico are expected to take action to prevent transshipment of steel articles through Canada and Mexico to the United States.
  • Other countries with which the U.S. has a “security relationship” may petition the Secretary of Commerce to remove or modify the restriction on imports of the designated steel and aluminum products from that country.
  • "Steel articles" subject to the tariff are defined at the Harmonized Tariff Schedule (HTS) 6-digit level as:
    • 7206.10 through 7216.50,
    • 7216.99 through 7301.10,
    • 7302.10,
    • 7302.40 through 7302.90, and
    • 7304.10 through 7306.90, including any subsequent revisions to these HTS classifications.
  • The steel order does not apply to downstream products made with steel or steel parts, such as: structures, reservoirs, tanks, containers, wire, etc.
  • “Aluminum articles” subject to the tariff are defined in the Harmonized Tariff Schedule (HTS) as:
    • ¬†(a) unwrought aluminum (HTS 7601);
    • (b) aluminum bars, rods, and profiles (HTS 7604);
    • (c) aluminum wire (HTS 7605);
    • (d) aluminum plate, sheet, strip, and foil (flat rolled products) (HTS 7606 and 7607);
    • (e) aluminum tubes and pipes and tube and pipe fitting (HTS 7608 and 7609); and
    • (f) aluminum castings and forgings (HTS 7616.99.51.60 and 7616.99.51.70), including any subsequent revisions to these HTS classifications.
  • The aluminum order does not apply to downstream products made with aluminum or parts of downstream products.
  • The Secretary of Commerce may, in consultation with other U.S. government agencies, provide relief from the additional duties for any steel or aluminum article determined not to be produced in the United States in a sufficient and reasonably available amount or of a satisfactory quality and is also authorized to provide such relief based upon specific national security considerations. Such relief shall be provided for a steel article only after a request for exclusion is made by a directly affected party located in the United States.
  • The Secretary of Commerce is to issue procedures for the requests for exclusion for steel and aluminum products not produced in the United States within 10 days after the date of the proclamations.

In light of these Presidential Proclamations new ACE programming is set to go into effect by end of business Tuesday, March 13, 2018. Both the PROD and CERT environments will be updated with the new HTS records.

For further information or questions about this and other customs issues, contact George R. Tuttle, III at or at (415) 986-8780.


George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in the San Francisco Bay Area.

The information in this article is general in nature, and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright © 2018 by Tuttle Law Offices.  

All rights reserved.  Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.


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