Section 232 Tariffs on Steel and Aluminum: Compliance Guide

What Is Section 232 and Why Does It Matter?

Section 232 of the Trade Expansion Act of 1962 authorizes the President of the United States to impose tariffs or other trade restrictions on imports that threaten national security. In March 2018, the Department of Commerce concluded that steel and aluminum imports threatened to impair US national security by undermining domestic production capacity critical to defense and infrastructure. Based on this finding, the President imposed a 25% tariff on steel imports and a 10% tariff on aluminum imports from nearly all countries. These tariffs remain in effect in 2026 and have become a permanent feature of the US trade landscape for metal importers.

Unlike most tariffs, Section 232 duties are imposed as a matter of national security rather than trade remedy or retaliation. This distinction matters legally — Section 232 tariffs are not subject to the same sunset provisions, injury determinations, or WTO dispute resolution processes that govern antidumping or countervailing duties. The tariffs apply broadly across product categories and countries, making them one of the widest-reaching trade measures in modern US history.

Current Tariff Rates and Product Scope

The current Section 232 tariff rates are 25% on steel articles and 25% on aluminum articles (the aluminum rate was increased from 10% to 25% effective March 2025). These tariffs are assessed as ad valorem duties on top of the normal MFN duty rate, meaning the total duty on a covered product can reach 30% or more when the base tariff is included. The product scope is defined by specific HTS codes identified in the presidential proclamations.

Steel Products Covered

• HTS Chapter 72: Iron and steel — including pig iron, ferroalloys, flat-rolled products, bars, rods, angles, shapes, sections, wire, tubes, and pipes.
• HTS Chapter 73: Articles of iron or steel — including structures, tanks, containers, wire products, chain, screws, bolts, needles, springs, stoves, and other fabricated steel products.
• Derivative steel articles: Certain downstream products containing steel as a primary component have been added to the scope through subsequent proclamations. These include steel nails, tacks, staples, bumper stampings, body stampings, and other processed steel products.

Aluminum Products Covered

• HTS Chapter 76: Aluminum and articles thereof — including unwrought aluminum, aluminum waste and scrap, powders, flakes, bars, rods, profiles, wire, plates, sheets, strip, foil, tubes, pipes, and other aluminum articles.
• Derivative aluminum articles: Additional downstream products have been brought under Section 232 scope, including certain aluminum castings, forgings, extrusions, and fabricated products.

Country-Specific Agreements and Exemptions

The Section 232 tariff landscape has been complicated by country-specific agreements that replace blanket tariffs with tariff-rate quotas (TRQs) or other arrangements. These agreements have changed multiple times since 2018, and the status varies by country and product type. As of early 2026, here is the general landscape for major trading partners.

• Canada and Mexico: Following the elimination of NAFTA-era exemptions in 2025, steel and aluminum imports from Canada and Mexico are subject to the full 25% Section 232 tariffs. This represents a significant change from the exemption these countries previously enjoyed and has major implications for North American supply chains.
• European Union: A tariff-rate quota (TRQ) arrangement replaced blanket tariffs for the EU, but the specifics have been renegotiated multiple times. Importers should verify the current TRQ allocation and whether their specific steel or aluminum products qualify for quota treatment.
• Japan: Japan negotiated a limited TRQ arrangement for certain steel products. Aluminum imports from Japan remain subject to the full 25% tariff.
• United Kingdom: The UK has a separate TRQ arrangement post-Brexit that mirrors but is distinct from the EU arrangement.
• All other countries: Most other countries (including China, Russia, India, Brazil, South Korea, Taiwan, and Turkey) are subject to the full 25% tariff on both steel and aluminum without quota relief.

The Product Exclusion Request Process

The Department of Commerce manages a product exclusion process that allows importers to request exemption from Section 232 tariffs for specific products. Exclusion requests must demonstrate that the specific product is not produced in the United States in sufficient quantity or quality, or that there is a specific national security reason to grant the exclusion. The process is administered through the Department of Commerce's Bureau of Industry and Security (BIS) and requires detailed product specifications, sourcing justification, and volume projections.

1. File the exclusion request through the 232 Exclusions Portal (exclusions.bis.doc.gov) with complete product specifications including HTS code, physical dimensions, chemical composition, and mechanical properties.
2. Provide justification explaining why the product cannot be sourced domestically — insufficient capacity, quality requirements not met by domestic producers, or specific technical specifications unavailable in the US market.
3. Domestic producers have 30 days to file objections to your exclusion request, claiming they can supply the same product. The Commerce Department evaluates both the request and any objections.
4. Decisions are typically issued within 90-120 days, though complex cases can take longer. Approved exclusions are retroactive to the filing date and valid for one year.
5. Exclusions are product-specific, not company-specific — any importer can use an approved exclusion for the same product. Monitor the Federal Register and the Commerce Department portal for exclusions that may apply to your products.

How to Verify If Your Product Is Covered

Determining whether your product is subject to Section 232 tariffs requires a multi-step verification process. First, confirm the accurate 10-digit HTS classification of your product. Then check whether the 8-digit HTS subheading appears on the Section 232 product list as specified in the presidential proclamations and subsequent amendments. If your product is on the list, determine whether any country-specific agreement provides quota relief for your source country. Finally, check whether any product-specific exclusion applies.

1. Classify your product accurately under the HTS — Section 232 applicability depends entirely on the HTS code, so classification errors can result in paying tariffs you do not owe or failing to pay tariffs that apply.
2. Cross-reference your HTS subheading against the Section 232 proclamation annexes (Presidential Proclamation 9705 for steel and 9704 for aluminum, plus subsequent amendments).
3. Check Chapter 99 of the HTS for the applicable secondary classification code (e.g., 9903.80.01 for steel at 25%).
4. Verify country of origin — the country of melt and pour (for steel) or country of smelting (for aluminum) determines Section 232 applicability, not the country of last substantial transformation.
5. Search the Commerce Department exclusion database for active exclusions that match your product specifications.

Interaction with Other Duty Programs

Section 232 tariffs stack on top of other applicable duties, creating complex total duty calculations for some products. The base MFN duty rate, Section 232 tariff, and any applicable Section 301 tariff (for Chinese-origin products) are all assessed cumulatively. For example, a steel product from China might face a 0-5% MFN duty, plus 25% Section 232, plus 25% Section 301 — for a total effective duty rate of 50-55%. However, Section 232 tariffs do interact with some preferential programs.

• USMCA: Section 232 tariffs apply regardless of USMCA qualification. A steel product that qualifies for zero duty under USMCA still pays the 25% Section 232 tariff. USMCA preferential treatment applies only to the MFN base rate.
• Section 301: Both Section 232 and Section 301 tariffs can apply to the same product if it is from China and made of steel or aluminum. The tariffs are cumulative.
• Antidumping and countervailing duties (AD/CVD): Section 232 tariffs are assessed in addition to any applicable AD/CVD orders. A steel product subject to AD/CVD duties from a specific country pays both the AD/CVD duties and the Section 232 tariff.
• Generalized System of Preferences (GSP): GSP duty-free treatment does not exempt products from Section 232 tariffs. The GSP benefit applies only to the MFN rate.
• Foreign Trade Zones (FTZ): FTZ benefits can defer but generally not eliminate Section 232 tariffs. When goods are withdrawn from an FTZ for consumption, Section 232 tariffs apply based on the classification and origin of the goods at the time of withdrawal.

The complexity of these overlapping duty programs makes accurate classification and origin determination essential. AI-powered tools like TariffPro automatically calculate the total effective duty rate across all applicable programs — MFN, Section 232, Section 301, AD/CVD, and preferential agreements — giving importers a complete picture of landed cost before they commit to a sourcing decision.

“Section 232 tariffs are not going away. They have become a structural feature of US trade policy, and every importer dealing in steel or aluminum products needs to treat them as a permanent cost factor in supply chain planning, not a temporary disruption to wait out.”

— Camtom Team