On 3 June 2025, President Donald J. Trump issued a proclamation titled "Adjusting Imports of Aluminum and Steel into the United States." This proclamation follows a series of investigations conducted under Section 232 of the Trade Expansion Act of 1962, which determined that imports of steel and aluminum articles pose a threat to national security. The Secretary of Commerce had previously reported that these imports are being brought into the United States (US) in such quantities and under such circumstances as to impair national security.

The proclamation builds on earlier actions, including Proclamations 9704 and 9705 (dated 8 March 2018), which imposed 25% ad valorem tariffs on aluminum and steel imports, as well as derivative articles.

Key provisions of new proclamation

Increased tariff rates

Effective 4 June 2025, the proclamation increases the tariff rate for imports of steel articles and derivative steel articles, as well as aluminum articles and derivative aluminum articles, from 25% ad valorem to 50% ad valorem. This increase is intended to provide greater support to domestic industries and reduce the national security threat posed by these imports.

Non-stacking principle maintained

Even with the increased tariff rates, the principle of non-stacking still applies. This means that if an article is already subject to other tariffs, it will not incur additional tariffs from the new adjustments for steel and aluminum imports. See EY Global Tax Alert, United States | Recent developments in US tariffs on automobiles and articles subject to tariffs, dated 30 April 2025.

Special treatment for United Kingdom

The proclamation specifies that the applicable rates of duty for articles imported from the United Kingdom will remain at 25% ad valorem. However, the Secretary of Commerce may adjust these rates or construct import quotas consistent with the US-UK Economic Prosperity Deal (EPD) if compliance is not met.

Monitoring and compliance

The Secretary of Commerce is instructed to continue monitoring imports of the affected articles and to review their status concerning national security. The Secretary will inform the President of any circumstances that may indicate the need for further action under Section 232.

Additionally, US Customs and Border Protection (CBP) issued guidance mandating strict compliance with declaration requirements for steel and aluminum content in imported articles. Importers who fail to comply may face significant penalties, including monetary fines and loss of import privileges.

Actions for businesses to consider

Affected companies should consider the following actions:

• Businesses should assess the implications of the increased tariffs on their import strategies and pricing structures.
• Companies should evaluate their supply chains to identify potential impacts from the new tariff rates and consider sourcing options.
• Consult with trade advisors to navigate the complexities of the new tariff structures and ensure compliance with updated regulations.