Trade Regulation Updates

On Monday, Feb.10, 2025, the US government signed an executive order instituting a 25% reciprocal tariff on foreign steel and aluminum. 

Neither an implementation date nor a complete list of HS codes affected has been announced. We will continue to monitor this situation and provide updates as they become available. 

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Feb. 11 Update - Additional details about the above executive order have been made public. The complete executive order can be found here. 

Several key points to note include: 

• The implementation date for these new tariffs is slated for March 12th, 2025. 
• The tariffs effectively end steel and aluminum quota arrangements with Argentina, Australia, Canada, Mexico, the EU, and the U.K. beginning on March 12th. 
• Some downstream products beyond those covered by Section 232 tariffs are newly covered by these tariffs. 
• The complete list of aluminum derivatives is expected to be released in a forthcoming annex. 
• No exclusions will be allowed from Section 232, and all general product exclusions will end on March 12th.

Feb. 18 Update - On Feb. 18, 2025, additional details, including details about derivative products that will be subject to the 25%, were released in two Federal Register notices. 

The notice regarding aluminum can be found here, and the notice regarding steel can be found here. 

Some of the items on the list of derivative products include:

• Steel and aluminum cookware
• Steel and aluminum furniture (9403.20.00)
• Aluminum doors, windows, and their frames (7610.10.00)
• Parts of lighting (9405.99.40) 
• Stoves, ranges, barbecues, etc., and related parts (7321)
• Parts for electric water heaters, hair dryers, and other similar household appliances (8516.90.8050)
• And many others.