NEW PROCLAMATION EXPANDS SECTION 232 STEEL & ALUMINUM RECIPROCAL DUTIES TO NON-METAL CONTENT
Section 232 duties on most imported steel and aluminum will rise from 25% to 50% at 12:01 a.m. EDT on June 4, 2025. The White House announced this change at U.S. Steel’s Mon Valley Works in West Mifflin, Pennsylvania on May 30th and formalized in a June 3rd proclamation.
“We are going to be imposing a 25% increase, bringing tariffs on steel into the United States of America from 25% to 50%, which will even further secure the steel industry in the United States.” White House Remarks on U.S. Steel
The increase covers every tariff line named in the February 2025 proclamations (Proclamation 10896 for steel and Proclamation 10895 for aluminum). The June 3 proclamation reaffirms that Section 232 duties apply to both base and derivative articles of steel and aluminum from nearly all countries with two key exceptions.
SECTION 232 STEEL AND ALUMINUM DUTY EXCEPTIONS
Section 232 duties are collected in addition to any antidumping, countervailing, or Section 301 measures already in force.
Tariff exceptions include:
Steel melted and poured, or aluminum smelted and cast, with certified origin in the United States, Canada, or Mexico remains duty-free.
Imports from the United Kingdom will continue to be subject to the 25 percent rate under the U.S.-UK Economic Prosperity Deal, pending review on or after July 9, 2025.
The Department of Commerce’s Bureau of Industry and Security shut down the Section 232 product-exclusion portal on February 10, 2025, and has not reopened it.
NON-STEEL AND NON-ALUMINUM CONTENT NOW SUBJECT TO ADDITIONAL TARIFFS
The June 3 proclamation marks a significant departure from previous policy. Until now, if a product was already subject to Section 232 steel or aluminum duties, its remaining non-metal content was not also subject to reciprocal tariffs. That separation no longer applies.
As of June 4, 2025, the non-steel and non-aluminum portion of any covered article may now be subject to tariffs under Executive Order 14257or other applicable trade programs. These duties will be calculated based on the declared value of non-metal content.
Importers must ensure complete and accurate HTS classifications and content breakdowns. CBP will issue enforcement guidance and has been directed to impose substantial penalties for underreporting or noncompliance, including monetary fines, suspension of import privileges, and potential criminal charges.
STEEL AND ALUMINUM TARIFF IMPACTS KEY INDUSTRIES
Manufacturers in construction, automotive, energy, aerospace, and durable goods sectors that rely on flat-rolled sheet, structural shapes, tubing, and precision extrusions will be among the most directly impacted by the tariff increase. Higher landed costs are expected to ripple through procurement, production, and inventory planning.
Some importers are advancing sailings to clear customs before June 3, while others are shifting orders to domestic mills. These shifts are tightening vessel, rail, and truck capacity, increasing demand for Foreign Trade Zone (FTZ) and bonded warehouse programs that defer duty, expanding single-transaction bond usage, and prompting U.S. producers to reassess offer prices.
ACTION PLAN: SECTION 232 STEEL, ALUMINUM, & IMPACTED NON-METAL CONTENT COMPLIANCE STEPS BEFORE JUNE 4
U.S. Steel and Aluminum importers should carefully review the following to ensure compliance:
Validate HTS codes for every open purchase order against those referenced in Chapters 72, 73, and 76
Secure melt-and-pour or smelt-and-cast certificates before cargo loads overseas to avoid clearance delays
Recalculate landed cost with the 50% duty plus existing trade remedies, then share updates with finance, sales, and planning teams
Confirm that higher declared values remain within marine cargo and stock throughput insurance limits
Evaluate alternate sourcing options, such as qualified mills in lower-risk jurisdictions or domestic electric-arc-furnace capacity
Audit available space at in-network Foreign Trade Zones to ensure inventory can be stored under duty-deferral programs
