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Adjustments to the 232 Tariffs

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 On June 3, 2025, an Executive Order (EO) was issued adjusting the Section 232 tariff on aluminum and aluminum derivative products (DPL) from 25% to 50%.  In addition to the adjustment in the 232 tariff, the EO also contains language that adjusts how the 232 tariff is applied. The following is a summary of the key points. 

  • Aluminum and aluminum derivative products within HTS Ch. 76 and outside HTS Ch. 76: the 50% duty applies only to the aluminum content.  Any non-aluminum content in these products will be subject to the reciprocal tariff (currently at 10%). 
    • This is a change from the February 10, 2025, EO for aluminum and aluminum derivative products in HTS Ch. 76 where the 232 tariff was applied to the full value of the product.  With the most recent EO, the 232 tariff now applies only to the aluminum content and the 10% reciprocal tariff applies to the non-aluminum content. 
  • The current EO also changes how the 232 Auto tariffs, 232 aluminum tariffs and the International Emergency Economic Powers Act (IEEPA) tariffs on Canada and Mexico are considered versus the Administration’s April 29, 2025 “de-stacking” order.  As a result of this order, one starts by assessing whether the Section 232 auto tariffs apply.  If they do not, then one looks to the Section 232 steel/aluminum tariffs.  If those apply, then the Canada/Mexico IEEPA tariffs will not apply.  This flips the order of the Section 232 steel/aluminum tariffs and the Canada/Mexico IEEPA in the de-stacking. 

  • This tariff increase does not apply to the aluminum and aluminum derivative imports from the UK.  Imports of aluminum and aluminum derivative products from the UK will remain subject to a 25% 232 tariff.  However, on July 9, 2025, imports from the UK may be subject to adjusted 232 tariff rates (or an import quota) based on their compliance with the US-UK Economic Prosperity Deal agreed to on May 8, 2025. 

As always, we will continue to monitor adjustments and amendments from the Administration and report as needed. 

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