The below represents information that was published on Friday, February 14th, 2025:

Aluminum

President Trump’s proclamation on aluminum increases the tariff rate on aluminum articles and derivative aluminum articles from 10% to 25% for all countries, except Russia. Imports of derivative aluminum articles from Russia, or those using primary aluminum (defined as new aluminum metal produced from alumina, or aluminum oxide, by the electrolytic Hall-Heroult process) smelted or cast in Russia, are subject to a 200% duty rate. The revised duty rates are “in addition to any other duties, fees, exactions, and charges applicable to such imported derivative aluminum articles.”

The White House published the annex that includes the list of aluminum derivatives that will face additional 25% tariffs, unless the aluminum content in them was smelted and cast in the US.

Eighteen of the tariff lines are in Chapter 76, which means the entire value will be tariffed; the other 104 are in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96, and only the aluminum content in those goods will face the tariffs.

Steel

The White House published its annex of steel derivative items that will be subject to Section 232 tariffs once CBP is ready to collect tariff revenue on those items. The 25 percent, Section 232 tariff on steel and steel-derivative articles will be extended to imports from all countries.

There are 155 derivative items in chapter 73, which will face 25% tariffs unless they are from Turkey; for steel products and derivatives from Turkey, a 50% tariff will be applied. The steel derivative annex includes items from HTSUS Chapters 73, 84, 85, and 94. The items in those chapters include bulldozer blades, parts of escalators and elevators, backhoe and front-loader attachments, plows, steel shelving, modular steel building units, brass lighting fixtures and other lighting fixtures.

“For purposes of implementing the requirements in this proclamation, importers of steel derivative articles shall provide to US Customs and Border Patrol within the Department of Homeland Security (CBP) any information necessary to identify the steel content used in the manufacture of steel derivative articles imports covered by this Proclamation. CBP shall implement the information requirements as soon as practicable,” the notice said.

Both proclamations terminate all current quotas, tariff-rate quotas, national exemptions, General Approved Exclusions (GAEs), and the product-specific exclusions application process. As a result, the Secretary of Commerce is directed to not consider or renew any product exclusion requests in effect as of 11:59 p.m. Eastern Standard Time on February 10th, 2025 and is also to rescind the product exclusion process. Specific, granted product exclusions will remain in effect until either their expiration date or until the specified excluded product volume is imported, whichever comes first. The GAEs will terminate on March 12th, 2025 (for the lists of GAEs, see Supplements No. 2 and No. 3 of 15 C.F.R. part 705). The Department of Commerce will issue Federal Register notices to provide further guidance on these changes.

The changes apply to both aluminum and steel products that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Standard Time on March 12th, 2025. President Trump has suggested that he is open to discussing new national exemptions before then; however, the likelihood of successfully negotiating new exemptions is unknown. If implemented, the tariffs will likely provoke retaliatory measures from other countries.

RIM will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative should you have any further questions.