What Are Section 232 Tariffs?
Section 232 of the Trade Expansion Act of 1962 allows tariffs on imports deemed a threat to national security. In 2018, the Commerce Department determined steel and aluminum imports threatened national security, triggering tariffs that remain in effect today.
Current Rates
- Steel: 25% ad valorem duty
- Aluminum: 10% ad valorem duty
- Applied in addition to regular Column 1 duties
- Stacks with Section 301 duties for Chinese origin
Country-Specific Arrangements
Tariff-Rate Quotas (TRQ)
- EU: Historical volume duty-free, above-quota at 25%
- UK: Quota system in place
- Japan: Negotiated TRQ for specific products
Exemptions and Modifications
- Canada/Mexico: Exempt under USMCA melt-and-pour requirements
- Australia: Full exemption
- South Korea: Absolute quota instead of tariff
Product Scope
Steel (HTS Chapters 72-73)
- Flat products: sheets, plates, strips
- Long products: bars, rods, wire
- Tubular products: pipes, tubes
- Stainless and alloy steel included
Aluminum (HTS Chapter 76)
- Unwrought aluminum
- Flat rolled products
- Bars, rods, profiles
- Foil and wire
Product Exclusion Process
Importers can request exclusions for specific products through the Bureau of Industry and Security (BIS) portal:
- Demonstrate product not produced in US in sufficient quantity/quality
- Submit through 232 Exclusions Portal
- Objection period for US producers
- Decision typically within 90-120 days
- Approved exclusions last 1 year
Melt-and-Pour Requirement
USMCA exemption requires steel to be melted AND poured in North America. Aluminum must be smelted AND cast. This prevents transshipment through Canada or Mexico to avoid tariffs.
Compliance Best Practices
- Maintain mill test certificates for country of origin
- Verify melt-and-pour documentation for USMCA claims
- Monitor TRQ fill rates for EU/UK imports
- File exclusion requests early for unique products
- Track quarterly quota updates from Commerce
Impact on Downstream Industries
Section 232 tariffs affect automotive, construction, machinery, and packaging sectors. Importers of finished goods containing steel/aluminum components should evaluate total landed cost impact. Specialty alloys and certain grades may qualify for exclusions.
