On June 3, 2025, President Trump signed a Proclamation increasing Section 232 tariffs on steel and aluminum imports, including derivative articles, from 25% to 50% ad valorem. The increase follows the reinstatement and expansion of these tariffs which became effective on March 12, 2025. (For information about the previous expansion, see our trade alert President Trump Announces 25% Tariffs on Steel and Aluminum.) The steel and aluminum tariff increase became effective at 12:01am Eastern Standard Time on June 4, 2025, and applies to goods entered for consumption or withdrawn from warehouses for consumption after that time.
Additional Impact
A few other important items to note from the Proclamation include:
- The Proclamation reverses earlier executive action and guidance with respect to the treatment of non-steel or non-aluminum content of derivative products. Non-steel and non-aluminum content of items subject to the steel and aluminum tariffs will now be subject to reciprocal tariffs and any other applicable tariff.
- The steel and aluminum tariff increase excludes imports from the U.K., which remains subject to a 25% tariff for such imports. But this could change after July 9, 2025, depending on the status of the U.S.-UK Economic Prosperity Deal.
- The Proclamation also amends Executive Order 14289 related to tariff “stacking” to give priority to the Section 232 tariffs on steel and aluminum over the International Emergency Economic Powers Act (“IEEPA”) tariffs on Canada and Mexico. (For further information on the initial tariff stacking Executive Order, see our previous trade alert, Trump Addresses Tariff Stacking and Provides Some Relief to Automakers.) CBP provided updated guidance on how the tariffs stack and interact with each other here.
Enforcement Priority
The Proclamation requires CBP to issue “authoritative guidance mandating strict compliance” with requirements for declaring steel and aluminum content of items subject to the tariffs. The forthcoming CBP guidance should also outline “maximum penalties for noncompliance, including that importers who submit underreported declarations may be subject to severe consequences, including but not limited to significant monetary penalties, loss of import privileges, and criminal liability.”
CBP Guidance
On June 3, CBP issued more specific guidance related to the increase in Cargo Systems Messaging Service (“CSMS”) messages. The updated guidance for the steel tariffs is found here and for aluminum tariffs here. The CSMS messages provide guidance regarding reporting steel or aluminum content, reporting multiple HTS codes, and Foreign Trade Zone treatment, among others.
