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President trump imposes section 232 tariffs




On Thursday, President Trump signed two Presidential Proclamations to impose additional Section 232 tariffs on steel and aluminum imports from all countries, except Canada and Mexico.  The tariffs are 25% for imported steel and 10% for imported aluminum.  These tariffs are imposed on top of existing customs duties and antidumping/countervailing duties (AD/CVD).


The actual Proclamations can be accessed here and here.  There are a number of details that will have to be further considered: 

  1. Effective DateThe proclamations indicate that they apply to all goods entered or withdrawn from warehouse for consumption beginning March 23.  This gives importers two weeks to make entry of products subject to the tariffs.  

  2. FTZs:  The Proclamations do not specifically state how they treat merchandise admitted into or entered from FTZs.  They state that the tariffs apply to goods entered or withdrawn from warehouse for consumption, which suggests they do not apply to FTZ admissions.  However, the recent residential washer and solar cells safeguard duties required subject products to be admitted into FTZs in Privileged Foreign (PF) status.  The treatment of FTZs may be clarified when Annexes to the Proclamations are published.  

  3. Scope (Part 1):  Not all steel and aluminum imports are covered.  The scope of steel and aluminum articles is detailed by HTSUS classification:    
  • Steel:  HTS 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;
  • Aluminum:  (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. 
  1. Scope (Part 2):  Products of Canadian and Mexican origin are excepted from the tariffs.  Expect efforts by Customs to verify the classification and origin of excepted goods.  

  2. Exclusions:  There will be a process to seek product exclusions.  These duties are based on national security concerns, so such considerations may be a useful basis for requesting a product exclusion.     
Please contact Sean Murray or Brian Murphy if you have any questions.


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Miller & Company is a law firm serving a diverse clientele in import, export, and foreign-trade zone law. Within these areas of specialized practice, we have received global recognition for our involvement in the development of the U.S. Foreign-Trade Zones Program.

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