US removes Section 232 tariff exemptions for 12 steel and aluminum products

The US will remove Section 232 import duty exemptions for six steel products and six aluminum products that were previously granted duty-free status due to their inclusion in the Commerce Department’s list of General Approved Exclusions, Commerce’s Bureau of Industry and Security said May 20.

Steel products again subject to the US’ 25% Section 232 tariff include those categorized under US Harmonized Tariff Schedule codes 7211296080, 7209900000, 7216330090, 7209270000, 7216100010 and 7208380015, according to a final rule published in the Federal Register.

Aluminum products again subject to the 10% Section 232 tariff include those categorized under HTS codes 7609000000, 7604210010, 7604291010, 7601209080, 7607116010 and 7604295090.

Steel, aluminum products removed from Section 232 GAE
HTS Product Category Description HTS Number
Flat-Rolled High-Strength Steel Of A Width >600 Mm, In Coils, Not Further Worked Than Hot-Rolled, Of A Thickness >3 Mm But <4.75 Mm 7208.38.0015
Flat-Rolled Iron Or Nonalloy Steel, Not Coils, 600 Mm Or More Wide ,Cold-Rolled (Cold-Reduced),Over 0.5Mm But Not Over 1Mm Thick, Not Clad Plated Or Coated 7209.27.0000
Flat-Rolled Iron Or Nonalloy Steel, Coils Or Not, 600Mm Or More Wide, Cold-Rolled, Not Clad, Plated Or Coated, Nesoi 7209.90.0000
Flat-Rolled Iron Or Nonalloy Steel, 300 To Under 600Mm Wide, Cold-Rolled, Not Clad, Plated Or Coated, 1.25Mm Or Less Thick, 0.25% Or More Carbon 7211.29.6080
Angles, Shapes And U Sections, Iron Or Nonalloy Steel,Hot Rolled, Hot Drawn,Less Than 80Mm High 7216.10.0010
Othr H Sections Iron Or Nonalloy Steel Hot-Rolled 80 Mm Or More High 7216.33.0090
Aluminum Alloy, Sheet Ingot (Slab) 7601.20.9080
Aluminum Alloy Hollow Profiles, Heat-Treatable Industrial Alloys 7604.21.0010
Aluminum Alloy Profiles, Heat-Treatable Industrial Alloys, Not Hollow 7604.29.1010
Aluminum Alloy Bars And Rods Having Other Than Round Cross Section, Nesoi 7604.29.5090
Aluminum Foil, Boxed, Weighing Lt=11.3 Kg, Of A Thickness Gt 0.01 Mm And Lt=0.15 Mm, Rolled, Not Backed 7607.11.6010
Aluminum Tube Or Pipe Fittings (Couplings,Elbows Sleeves) 7609.00.0000

The changes are effective July 1.

The US implemented the steel and aluminum tariffs on imports from all countries in March 2018 by utilizing a provision in the Trade Expansion Act of 1962 allowing the government to impose tariffs in response to alleged national security threats.

The duties have since been modified over the years for specific countries and products. For instance, Canada and Mexico are exempt from the duties while the tariff has been modified to a quota system for the EU.

Cumulatively, US imports of the 12 subject products for which the duty exemptions are now revoked have more than tripled since the 2018 tariffs. Total import volume for these products was over 1.2 million mt in 2023, compared with about 340,000 mt in 2017, according to Commerce data.


Tariff exclusion filing

In August 2018, Commerce authorized a system in which importers could request shipments of specific products to be excluded from the Section 232 tariffs if certain criteria were met, such as a lack of domestic capability to supply a product at necessary quality specifications. Domestic producers are eligible to challenge exclusion requests. With no challenge, the exclusion request has a greater chance of being approved by Commerce.

Commerce has since published five interim final rules and collected public feedback to improve the exclusion request process.

One of these interim rules, issued in late 2020, established a GAE list of 123 steel and aluminum products that would automatically be exempt from the tariffs without the need for importers to file a tariff exclusion request. The list included imported products that were frequently granted exemptions without challenges from domestic producers. The objective of the GAE list was to reduce the number of exclusion request filings, which number in the thousands.

Some industry participants have criticized the tariff exemption process and GAE list for weakening the intent of the Section 232 duties. Others argue that the filing process is burdensome, with significant resources necessary to file, review and challenge the high volume of request filings. For instance, Commerce said the upcoming removal of the 12 subject metal products from the GAE could result in an increase of 1,000 exclusion request submissions per year.

Commerce already removed 30 GAE products in 2021 in response to industry feedback. In August 2023, the department proposed changes to exclusion criteria and introduced a list of General Denied Exclusions, products that were not eligible for tariff exemptions.

The GAE list now contains 81 steel and aluminum products.

Author Nick Lazzaro,