THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE	Steel/Aluminum Tariffs Increased from 25% to 50% and Additional Changes to Scope
DATE	June 3, 2025
AGENCY	Department of Homeland Security, Department of Commerce, Customs and Border Protection (CBP), Trump Administration
EFFECTIVE DATES	June 4, 2025, 12:01 a.m. Eastern Time
BACKGROUND	On February 10, 2025, the President issued Proclamations placing 25% tariffs on steel and aluminum items (and certain derivative articles), effective March 12, 2025.   The previous Proclamations instructed the Secretary of Commerce to continue monitoring imports of derivative steel and aluminum articles. Based on current information provided by the Secretary, the President has determined additional action is needed to protect U.S. interests.
DETAILS	The current Proclamation expands the applicability of the steel/aluminum tariffs by the following actions. We emphasize that the Proclamation cites three Annexes that have not yet been issued at the time of publishing. Notwithstanding, the text of this Proclamation:   • Increases tariffs on steel/aluminum and their derivative articles (as defined in Annexes I and II) to 50%, effective June 4 at 12:01 a.m. It is not yet clear whether Annexes I and II contain articles currently subject to steel/aluminum tariffs or if they expand the scope of items subject to these tariffs. • Revises (as of June 4, 2025) the application of reciprocal tariffs so that non-aluminum and non-steel content is subject to reciprocal tariffs “and any other applicable tariffs.” • While Annex III has not been released, we read the order and the CSMS message #65236574 to revise section 3(a)(ii) of the “tariff stacking” EO to prioritize steel/aluminum tariffs over Canada/Mexico tariffs. Since articles can either be exclusively subject to (1) steel/aluminum tariffs or (2) Canada/Mexico tariffs, it appears this revision of language dictates that steel/aluminum tariffs take precedence and will apply to such articles subject to both. The Section 232 action on autos and auto parts still takes precedence over the above tariffs. • Modifies the U.S.-UK trade deal to maintain 25% tariffs on steel/aluminum articles and their derivatives from the United Kingdom until July 9. On or after July 9, 2025, the Secretary may adjust the rates and quotas for steel/aluminum from the UK to 50%. • Articles entered into FTZs under privileged foreign status will be subject upon entry for consumption to the tariff,effective at the time of entry for consumption. • The White House threatens a further “crack down” on false import declarations that avoid the duties. • No drawback is available with respect to the duties announced in this action.
BASIS	Section 232 of the Trade Expansion Act; International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.); Section 301 of Title 3, United States Code; and Section 604 of the Trade Act of 1974
HTS/PRODUCTS	Steel and aluminum articles as defined in Annexes I and II (not yet published)
COUNTRY	All
CITE	Adjusting Imports of Aluminum and Steel into the United States – The White House CSMS # 65236574 -UPDATED GUIDANCE – Proclamation “Adjusting Imports of Aluminum and Steel in the United States,” Amending Executive Order 14289, “Addressing Certain Tariffs on Imported Articles” CSMS # 65236645 – UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products CSMS # 65236374 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products Fact Sheet: President Donald J. Trump Increases Section 232 Tariffs on Steel and Aluminum – The White House

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