The measures adopted by the United States fall under Section 232, the instrument that allows the imposition of restrictions or tariffs on imports for national security reasons.

During 2025, the U.S. Administration has reactivated and expanded this regime, doubling tariffs and extending them to a wide range of downstream products incorporating these metals.

Given the complexity of these developments and their relevance to AMEC members, we have prepared a detailed timeline between February and September 2025.

The objective is to provide a practical tool to identify the main changes and how these measures may affect exports of industrial goods to the U.S. market.

February 10, 2025 – Start of the new regime

Documents:

• Proclamation 10895 – Adjustment of aluminum imports. https://www.federalregister.gov/documents/2025/02/18/2025-02832/adjusting-imports-of-aluminum-into-the-united-states
• Proclamation 10896 – Adjustment of steel imports. https://www.federalregister.gov/documents/2025/02/18/2025-02833/adjusting-imports-of-steel-into-the-united-states

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Substantive developments:

• Reimpose 25% ad valorem tariffs on all steel and aluminum imports, including by-products.
• They introduce the distinction between “wholly of steel and aluminum” (basic products of chapters 72, 73 and 76) and “derivatives” (articles containing steel and aluminum as components).

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March 5, 2025 – Initial Technical Implementation

Document: BIS Notice – Implementation of Duties on Steel Pursuant to Proclamation 10896. https://www.federalregister.gov/documents/2025/03/05/2025-03598/implementation-of-duties-on-steel-pursuant-to-proclamation-10896-adjusting-imports-of-steel-into-the

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Substantive developments:

• Reflects in the HTSUS the distinction between products wholly of steel and steel products by incorporating heading 9903.81.xx.
• Defines the rule that when a product is not made entirely of steel, the 232 tariff is calculated only on the declared value of the steel content, not on the total value of the good.

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June 9, 2025 – Duplication of tariffs

Document: Presidential Proclamation 10947 – Adjusting Imports of Aluminum and Steel Into the United States. https://www.federalregister.gov/documents/2025/06/09/2025-10524/adjusting-imports-of-aluminum-and-steel-into-the-united-states

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Substantive changes: Increases tariffs from 25% to 50% on all steel and aluminum products and their derivatives.

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June 16, 2025 – First extension of derivative products (Steel)

Document: BIS Notice – Implementation of Duties on Steel Pursuant to Proclamation 10896 (Revised Annex 1). https://www.federalregister.gov/documents/2025/06/16/2025-11067/implementation-of-duties-on-steel-pursuant-to-proclamation-10896-adjusting-imports-of-steel-into-the

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Substantive developments:

Adds 8 steel products to the tariff schedule (HTSUS):

• 8418.10.00 combined refrigerators,
• 8418.30.00 / .40.00 freezers,
• 8422.11.00 dishwashing machines,
• 8450.11.00 / .20.00 washing machines,
• 8451.21.00 / .29.00 dryers,
• 8516.60.40 ovens and ranges,
• 8509.80.20 waste shredders,
• 9403.99.9020 Metal shelving.

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August 19, 2025 – Major expansion of steel and aluminum products

Document: BIS Notice – Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process (August 2025). https://www.federalregister.gov/documents/2025/08/19/2025-15819/adoption-and-procedures-of-the-section-232-steel-and-aluminum-tariff-inclusions-process

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Substantive developments:

• 407 new HTSUS codes for steel and aluminum products are added.
• The categories mainly cover:
  • Chapters 82-83: tools, hinges, fasteners, cutlery, hardware.
  • Chapters 84-85: motors, generators, transformers, cables, electrical appliances.
  • Chapter 87: vehicles, trailers, chassis, parts of mobile machinery.
  • Chapter 94: metal furniture, structures, accessories.
  • Some processed aluminum products (composite sheets, profiles, components).
• He informed that another 60 items were under evaluation for the next round.

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There is no “232 list”.

In short, there is not a list of codes that is being updated, but a series of proclamations.

The most practical and secure system is to consult the different online tools where the applicable tariffs per item can be consulted.

Practical criteria to distinguish how the 50% tariff is applied:

A. Products “entirely of steel or aluminum”: These are primary or semi-finished metallic products. 50% of the total value.

• Steel: Chapters 72 and 73.

• Aluminum: Chapter 76.

B. Derivative” products: Any other article classified outside these chapters, even if made partly or mainly of steel or aluminum. Tariff applied only on the value of the metal content.

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Practical example

In the case of exports from the EU to the US, we recommend using the EU Access2Markets portal, where you will be able to check the specific tariff applied to your specific items.

https://trade.ec.europa.eu/access-to-markets/es/home

For example, heading 8450.11.0010 (automatic coin-operated washing machines), included in one of the extensions, would belong to the derived products group.

A query of this item in Access2Markets for an export from the EU to the USA gives the following result:

As can be seen, the presence of 50% of FOB value indicates that it is affected by Section 232.