On February 10, 2025, President Trump signed proclamations expanding the existing 25% tariffs on steel articles and increasing the tariffs on aluminum imports from 10% to 25% under Section 232 of the Trade Expansion Act of 1962, as amended (Section 232). The proclamation revokes all current alternative arrangements under the Section 232 regime and reimposes tariffs on imports of steel and aluminum articles from all countries, including Canada, Mexico and the European Union (EU), effective March 12, 2025. In addition, the proclamations immediately terminate the product-specific exclusion process set forth in the prior actions.

The February 10 proclamation generally takes effect March 12, 2025, with some immediate interim impacts:

• Aluminum Duties Increase: The proclamation directs an increase in aluminum import tariffs to 25% for all U.S. imports as of 12:01 ET on March 12, 2025.
• Alternative Arrangements Revoked: The proclamation revokes the alternative arrangements, including absolute quotas, tariff rate quotas and country exemptions, made with respect to countries and regions including Argentina, Australia, Brazil, Canada, Mexico, the EU, the United Kingdom, Japan and Korea for all U.S. imports as of 12:01 ET on March 12, 2025. As of that date, imports of steel articles from all countries will be subject to the Section 232 tariffs that were imposed during President Trump’s first term.
• No Exclusions: The Section 232 product-specific exclusion process is terminated, effective immediately (11:59 PM ET on February 10, 2025), with the portal currently deactivated. Commerce is directed not to consider or grant any exclusion requests as of February 11, 2025. However, granted product exclusions will remain effective until their expiration date or until excluded product volume is imported, whichever occurs first. Commerce is directed to terminate all existing general approved exclusions (GAEs) as of March 12, 2025. 
• Subject Products: As of March 12, 2025, certain derivative steel and aluminum products (not yet defined) will become subject to Section 232 tariffs in addition to upstream steel and aluminum products covered in the original proclamations implementing the Section 232 tariffs. The lists of the derivative products will be published in the Federal Register and are not yet available, so the scope as it relates to prior actions on steel and aluminum derivatives is unclear. Derivative products produced with steel melted and poured in the United States or aluminum extruded in the United States will not be subject to the expanded Section 232 tariffs, and for all other derivative products, the new tariffs will be assessed on the value of the underlying steel. 
• Inclusion Process: Within 90 days after the date of the proclamation (i.e., no later than mid-May 2025), Commerce is directed to establish a process for including additional derivative steel products within the scope of the Section 232 tariffs. When Commerce receives a request from a domestic producer/industry association, Commerce is directed to determine whether to include the derivative products within the scope of the Section 232 tariffs within 60 days of receiving the request. 
• CBP’s Enhanced Oversight: The proclamation directs U.S. Customs and Border Protection (CBP) to enhance oversight to prevent tariff evasion through the misclassification of steel products. Should CBP discover misclassification resulting in non-payment, CBP is directed to assess monetary penalties in the maximum amount permitted by law and to not consider any evidence of mitigating factors. 
• No Drawback: No drawback will be available with respect to the expanded Section 232 tariffs. 
• FTZ: For steel and aluminum articles or derivative articles that are admitted into a U.S. foreign trade zone (FTZ) on or after 12:01 AM ET on March 12, 2025, those products must be admitted in either domestic status or privileged foreign status, and articles that were admitted into a U.S. FTZ under privileged foreign status prior to, on, or after 12:01 AM ET on March 12, 2025, will be subject to the Section 232 tariffs imposed under this February 10 proclamation upon entry for consumption.

The White House Fact Sheet accompanying the proclamation highlighted that the expanded Section 232 action is to protect and restore fairness for the U.S. critical steel and aluminum industries harmed by unfair trade practices and global excess capacity. According to the Fact Sheet, the expanded Section 232 action is designed to eliminate loopholes that facilitated circumvention and diminished the effectiveness of the original Section 232 actions under previous proclamations.