Aluminum and Steel Tariffs Doubled Starting Today

Washington, DC, 4 JUNE, 2025 – Last Friday, Trump announced that he was going to double aluminum and steel tariffs from 25% to 50%. Yesterday evening, less than 24 hours before the start of the doubling of the aluminum and steel tariffs, the White House released a Presidential Proclamation to provide the details regarding the increase in the aluminum and steel tariffs. Among the "highlights" of the proclamation are:

1. Section 232 tariffs on aluminum and steel from the United Kingdom will remain at 25% - for all other countries that previously faced a 25% Section 232 tariff on aluminum and steel, including derivative products, the rate will double to 50% starting 12:01 am EST today (June 4, 2025)
2. For articles that were previously entered into a foreign trade zone (FTZ) in "privileged foreign status" (which normally locks in the tariff treatment applicable to the article when it enters the FTZ), and that are listed in Annex II to the proclamation, the duty rate that will apply to such privileged foreign merchandise when it leaves the FTZ will be the rate in effect at the time of withdrawal from the FTZ, not the rate when the goods were designated as privileged foreign merchandise.
3. The White House removed some of the tariff relief it had previously provided whereby Canadian and Mexican origin goods that were subject to the 25% fentanyl tariffs were not subject to the Section 232 tariffs on aluminum and steel. Yesterday's proclamation reverses the White House's prior relief so that goods that are subject to the Section 232 tariffs on aluminum and steel will not be subject to the fentanyl tariffs on Canadian and Mexican origin goods (i.e., such goods have to pay the new, higher 50% tariff).
4. The White House previously had said, in the case of aluminum and steel derivative products that the non-aluminum/non-steel portion of such goods would not be subject to any reciprocal tariffs, but today's announcement states that reciprocal tariffs will, in fact, apply to the non-aluminum/non-steel portion of the goods – thereby making the entire value of the good subject to some sort of tariff.
5. The White House again admonished all who dare make a mistake in importing that U.S. Customs and Border Protection (CBP) is to issue "authoritative guidance mandating strict compliance with declaration requirements for steel and aluminum content in imported articles and outlining 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, consistent with United States law."

As if the above were not enough, today (June 4th) is the deadline for importers and the public to file comments in opposition to the Department of Commerce massively expanding the list of aluminum and steel derivative products. As we noted in a prior alert, not only will existing aluminum and steel products (including derivatives) be hit with 50% tariffs, there will likely soon be more products covered by the increased tariffs. While there is still time to comment on the proposed expanded coverage of aluminum and steel tariffs, importers must act quickly as the deadline for filing comments is today. Our unofficial list of the HTSUS codes currently being proposed for inclusion in the aluminum and steel tariffs are attached. The official posting of the proposed expansions may be found here.