Additional Duties on Steel and Aluminum Imports

Actions include the following, and more information will be forthcoming when the EOs are published with their annexes in the Federal Register and when the Department of Commerce (Commerce) and Customs and Border Protection (CBP) issue operational instructions.

Steel and Aluminum: 

• Effective date: February 10, 2025 for product exclusion process and March 12, 2025 for country exemptions and general approved exclusions.
• All country exemptions are terminated effective March 12, 2025, including those with absolute or tariff-rate quotas: Argentina, Australia, Brazil, Canada, EU countries, Japan, Mexico, South Korea, United Kingdom, and Ukraine. 
• General approved exclusions: All general approved exclusions are terminated effective March 12, 2025.
• Product exclusions: Effective February 10, 2025, Commerce will not consider any product exclusion requests or renew any product exclusion requests. Exclusions already granted will remain effective until their expiration date or until the excluded product volume is imported, whichever occurs first. 

Steel and Aluminum Derivatives:

• Effective date: TBD – the effective date will be determined when Commerce advises that adequate systems are in place to declare the associated duty. 
• Excluded: Derivative steel articles processed in another country from steel articles that were melted and poured in the United States and derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States. 
• Dutiable value: The duty will be applied to the value of the steel content used in the manufacture of the steel derivative article and the value of the aluminum content used in the manufacture of the aluminum derivative article. CBP is tasked with providing instructions necessary to identify the steel and aluminum content. 
• Additional articles: By April 10, 2025, the Secretary of Commerce shall establish a process for including additional derivative steel and aluminum articles to the scope. Other than additions made by the Secretary, producers or industry associations may submit a request for an addition by establishing that imports of a derivative steel or aluminum article have increased in a manner that threatens to impair the national security or otherwise undermine the objectives of these actions. Commerce is directed to render a decision within 60 days of such requests.

 Steel and Aluminum and Derivatives:

•  Foreign trade zones: On the respective effective dates, admissions to an FTZ must be admitted as privileged foreign status, unless eligible for admission under domestic status.
•  Penalties: CBP shall prioritize reviews of entries of steel and aluminum and derivative articles. If it discovers misclassification resulting in non-payment of these duties, it shall assess monetary penalties in the maximum amount permitted by law and shall not consider any evidence of mitigating factors in its determination. In addition, CBP shall notify Commerce regarding evidence of any efforts to evade these duties through processing or alteration of steel or aluminum articles or derivative steel or aluminum articles prior to importation, in which case Commerce shall consider the articles for inclusion as derivative steel articles. 
• Drawback: No drawback of these duties will be permitted. 

We will share updates as they become available. Please reach out to your Schenker contact with any questions.