Late yesterday, President Donald Trump issued a Proclamation to increase tariffs from 25% to 50% on steel and aluminum products and their derivatives listed in yet-to-be-released product Annexes. The higher rate went into effect on goods entered for consumption starting this morning, Wednesday, June 4 at 12:01 am EST.
These actions are particularly relevant to ASA members who import any of the following covered HTS codes:
- 30.2000 – Fishing Reels Valued Not Over $2.70 Each
- 30.4000 – Fishing Reels Valued Over $2.70 But Not Over $8.45 Each
- 30.6000 – Fishing Reels Valued Over $8.45 Each
- 30.8000 – Fishing Reels Parts And Accessories
- 90.6000 – Fishing Landing Nets, Butterfly Nets And Similar Nets
In addition to the higher tariff rate, the Proclamation also requires the non-metal content in product derivatives to be subject to IEEPA reciprocal tariffs, which are 10% for all countries except China until July 9 and 10% for China until August 12. Previously, the non-metal content in steel- or aluminum-containing product derivatives were not subject to the additional IEEPA tariffs.
The Proclamation also flips the previous stacking rules for steel and aluminum from Mexico and Canada subject to the 50% rate instead of the IEEPA fentanyl/border tariffs (25%/10% rates).
The action does not impact the application of Section 301 or IEEPA fentanyl tariffs on Chinese-origin goods.
A fact sheet detailing the action can be found here.
CBP implementation guidance for steel products can be found here, while the one for aluminum can be found here, and guidance on stacking can be found here. Note that the steel and aluminum product lists attached to CBP’s CSMS guidance are likely the referenced “Annexes” – we will not be able to confirm until the Federal Register notice is posted
A breakdown of how we are reading the Proclamation is below:
- Tariffs increased to 50% on products listed in Annexes I and II (not yet released).
- Tariffs remain at 25% on products listed in Annex III (not yet released).
- Tariffs remain at 25% for products originating in the United Kingdom.
- On or after July 9, the Secretary may increase the tariff rate to 50% and/or construct a quota limit consistent with the U.S.-UK Economic Prosperity Deal.
- Based on the product lists attached to CBP’s guidance, no new products were added to the existing list of impacted products.
- Tariff stacking of Section 232 steel and aluminum tariffs with Canada/Mexico IEEPA fentanyl/border tariffs is now flipped, meaning affected products from Canada and Mexico are now subject to the 50% rate increase but are no longer subject to IEEPA fentanyl/border tariffs (25%/10% rates).
- We do not know yet if USCMA-qualifying products will be similarly impacted.
- Product Derivatives (products not classified in Ch. 73 and 76):
- The non-metal content in product derivatives will now be subject to IEEPA reciprocal tariffs.
- There is not an on-the-water transit exception.
- No drawback is allowed on these duties.
- S. Foreign Trade Zones (FTZs):
- Annex I: Products must be entered as PFS, and will be subject to ad valorem duty rates in place at time of admission.
- Annex II: Any PFS products entered into the zone prior to June 4 and then entered for consumption after June 4 shall be subject to the duty rates applicable to the HTSUS of the product in effect at the time of entry for consumption.
Tariff Update Webinar
On Jun 6, 2025 at 12:00 PM ET, ASA and our trade firm, Sorini, Samet & Associates, will host an ASA-member webinar to explain these latest developments and answer questions. Click here to register.
We are following these developments closely and will provide relevant information as it develops. In the meantime, please do not hesitate to reach out with any questions.
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