Duties increase to 50% and Comments Due to Department of Commerce Today
Following through on a social media post from this past weekend, U.S. President Trump issued a Presidential Proclamation on June 3, 2025 that declares an increase from 25% to 50% on imported steel and aluminum effective 12:01 a.m. ET June 4, 2025.
The proclamation has key changes importers will need to heed, including:
- Mexico and Canada: Imported steel and aluminum goods subject to the Section 232 tariffs will not be subject to the fentanyl tariffs on Canadian and Mexican origin goods. Previously, goods subject to fentanyl tariffs on Canadian and Mexican origin goods were exempt from steel and aluminum Section 232 tariffs. The stacking order has been swapped. This means that the 50% duty rate for steel and aluminum imports now has priority over fentanyl tariffs on Canadian and Mexican goods, effective today.
- Products containing derivatives: According to trade attorney Michael Roll, the “White House previously had said, in the case of aluminum and steel derivative products that the non-aluminum/non-steel portion of such goods would not be subject to any reciprocal tariffs, but today’s announcement states that reciprocal tariffs will, in fact, apply to the non-aluminum/non-steel portion of the goods…”
- For derivative steel and aluminum goods with non-steel or non-aluminum content – exemption from the IEEPA Reciprocal duties under 9903.01.33 is no longer in effect as of today for the non-metal portion of the good. However, products of Canada and Mexico are still exempt from reciprocal duties under their country-specific exemptions.
- All non-metal content of a good that was split to pay Section 232 duty now has to pay the IEEPA Reciprocal Baseline duty of 10% under Harmonized Tariff System code 9903.01.25, unless another exemption from reciprocal duties applies.
- Chapter 73 and Chapter 76 duty due only on steel and aluminum content: All articles and derivative articles classified in Chapter 73 and Chapter 76 subject to 232 duties, the 50% duty (25% for products of the UK) is to be reported with the Chapter 99 classification based upon the value of the subject metal content. This means that articles classified in Chapters 73 and 76 that previously had duty due on the full value of the article can now declare the value of the subject metal content for 232 duty calculation purposes and the non-metal content will be subject to reciprocal duties.
- Foreign Trade Zones (FTZs): Goods previously entered into an FTZ under “privileged foreign status” (which previously applied the tariff rate to the goods based on the date of admittance into the FTZ), and that are listed in Annex II of the Proclamation (which will be published in the Federal Register) are now subject to the duty rate that is in effect on the date the goods are withdrawn from the FTZ and entered for consumption.
- United Kingdom: The Section 232 tariffs on aluminum and steel from the United Kingdom will remain at 25% – for all other countries that previously faced a 25% Section 232 tariff on aluminum and steel, including derivative products, the rate will double to 50% starting today.
- Enforcement: The White House warned that importers who submit underreported declarations may be subject to severe consequences, including maximum penalties for noncompliance.
Deringer also notes that today is a key deadline for importers wishing to communicate opposition to the Department of Commerce increasing the list of aluminum and steel derivative products. Should the Department follow through with expanding the list, existing aluminum and steel products (including derivatives) will be subject to 50% tariff rate. Harris & Roll has published a helpful and ‘unofficial’ list of the HTSUS codes currently being proposed for inclusion in the aluminum and steel tariffs, while the official posting of the proposed expansions may be found here.
A.N. Deringer, Inc. will continue to monitor the Federal Register, White House, and U.S. Customs and Border Protection official notifications, as well as the alerts posted by our partners and stakeholders, to keep our customers apprised of U.S. tariff changes and relevant policy changes.
Sources: NCBFAA, Roll & Harris LLP
Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.
