Update on USA tariffs

11 March 2025

The U.S. administration has recently adopted implementing measures for the entry into force of additional tariffs on steel, iron, and aluminum, along with the publication of two Cargo Systems Messaging Service (CSMS) guidance notices. Modifications have also been introduced to the previous additional tariff measures for Mexico and Canada.

Here are the main updates:

• MEXICO and CANADA: starting from March 6, products originating from either of these two countries, if falling within the scope of the USMCA (United States-Mexico-Canada Agreement), are not subject to the additional ad valorem rate of duty of 25% implemented on March 4. This measure will apply until April 2 and does not cover the importation of petroleum, natural gas, or other energy products from Canada, for which the additional 10% tariff still applies.
• ALUMINUM, IRON, STEEL: starting March 12, the additional ad valorem rate of duty of 25% will apply to iron, steel and aluminum products, all other than those with United States origin, including those under free trade agreements. The additional tariff also applies to specific derivative aluminum, iron, or steel products, as  identified in the regulation.

 

President Trump also announced the introduction of "reciprocal" tariffs on U.S. imports starting from April 2, 2025.

The Customs Consultancy team continues to monitor the situation and remains at your disposal for any further information.

 

4 March 2025

With the publication of two guidance notices on the Cargo Systems Messaging Service (CSMS) on Monday, March 3, U.S. Customs and Border Protection announced the effective implementation of the additional ad valorem duty measures imposed on Mexico and Canada. An update on the additional tariffs applied to products originating from China and Hong Kong was also published.
Starting from March 4, 2025, the United States has implemented the following additional ad valorem duties on imports:

• MEXICO: An additional ad valorem rate of duty of 25% on imports of products originating from Mexico;
• CANADA: An additional ad valorem rate of duty of 25% on imports of products originating from Canada; for imports of oil, natural gas or other energy products, an additional ad valorem rate of duty of 10% will apply;
• CHINA AND HONG KONG: An additional ad valorem rate of duty of 20% on imports of products originating from China and Hong Kong, replacing the 10% duty rate applied since February 4.
   

Specific exclusions are provided for products intended for donations, humanitarian purposes, and informational material.

The possibility of applying the de minimis exemption for shipments up to $800 is confirmed, a provision that particularly benefits e-commerce or international postal network and allows duty-free imports into the USA of low value shipments.

 

24 February 2025

On February 18th, two Proclamations – nr. 10895 and 10896 – were published in the Federal Register, providing details regarding the application of additional duties equal to 25% on steel and aluminum. In particular, the two documents:

• reiterate that the application of the additional duty will be effective, starting from 03/12/25, on all products derived from aluminum and steel or containing aluminum or steel parts, regardless of origin, with the sole exception of aluminum and steel products obtained from U.S. origin aluminum or steel – in this case, the exemption requires proof by the importer;
• emphasize that the additional duty equal to 25% on steel and aluminum is to be considered applicable in addition to the standard duty but also to any anti-dumping measures or countervailing duties provided for on certain HTSUS codes;
• revoke the measures taken by the previous administration and aimed at reducing the impact of the additional duties already in force for aluminum, steel and products obtained from them, of Argentine, Australian, Brazilian, Canadian, Mexican, EU, UK, Japanese, South Korean origin;
• list the HS codes affected by the measures, based on the U.S. Customs Tariff: the lists include not only aluminum, steel and products obtained from them, but also some product categories that may include parts in aluminum or steel; for this second category, the additional duty will be applied only to the aluminum and steel parts of the products themselves.

 

12 February 2025

President Trump on Monday, February 10, 2025, imposed a 25% tariff on all steel and aluminum imports into the U.S. with no exceptions or exemptions, to begin effective 12:01AM EDT, March 12, 2025.

• The 25 percent Section 232 tariff on steel and steel derivative articles will be extended to imports from all countries.
• The 10 percent Section 232 tariff on aluminum and aluminum derivative articles will be increased to 25 percent and extended to imports from all countries.

Effective March 12, duties will be reinstated as to countries previously exempted.

These tariffs will be extended to additional derivative articles (which will be identified in annexes to the proclamations that had not been published at press time, and a process for further expansion will be established), with exceptions for those processed in another country from steel articles melted and poured, or aluminum articles smelted and cast, in the U.S.

The alternative agreements for Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, Ukraine, and the UK will be terminated.

All existing general approved exclusions from the tariffs will be terminated (though granted product exclusions will remain in effect until their expiration date or until their excluded volume is imported, whichever occurs first, and the process for requesting exclusions has been terminated as of Feb. 10).

However, both proclamations include language suggesting that tariffs on derivative articles will not take effect until the Department of Commerce provides public notification that adequate systems are in place to fully, efficiently, and expediently process and collect associated tariff revenue, though it is unclear which articles this suspension will apply to.

The steel and aluminum tariffs affect products in the following Harmonized Tariff Schedule (HTS) classifications: 

• Steel: 7206.10 through 7216.50, 7216.99 through 7301.10, 7302.10, 7302.40 through 7302.90, and 7304.10 through 7306.90;
• Aluminum: 7601 (unwrought aluminum), 7604 (bars, rods, and profiles), 7605 (wire), 7606 and 7607 (plate, sheet, strip, and foil), 7608 and 7609 (tubes and pipes), 7616.99.51.60 and 7616.99.51.70 (castings and forgings).

We are monitoring and will continue to update as changes occur.

 

4 February 2025

We inform you that following political agreements made yesterday, President Trump has decided to suspend for one month the application of tariffs on goods coming from Canada and Mexico.

The decision regarding China remains unchanged, and the additional tariffs will take effect starting today, Tuesday, February 4, 2025. The new tariff measures will be added to the rates already in place for China.

However, goods in transit starting from February 1, 2025, when the executive order was signed, will not be subject to the additional tariffs.

The door remains open, however, for tariffs with China, with whom President Trump will be speaking in the coming hours. For now, the Chinese government is considering implementing a package of measures targeting American coal and liquefied natural gas (LNG) with additional tariffs of 15%, as well as a 10% tariff on oil, agricultural equipment, and some automobiles.

There will likely be developments in the coming days. We will continue to monitor the situation and inform you of any updates.

 

3 February 2025

We inform you that starting from February 4th, 2025, the United States has decided to impose additional duties on products imported from China, Mexico, and Canada.

In his executive action, the Trump administration declared a national economic emergency, invoking the International Emergency Economic Powers Act, known as "IEEPA", which authorizes the president to manage imports during a national emergency unilaterally. Trump stated that the purpose of the additional duties is to limit the flow of migration and the illegal entry of drugs, particularly Fentanyl, into the United States. However, these measures may lead to substantial price increases for American consumers.

The additional tariffs will be equal to 25% on imports from Mexico and Canada, except for some categories of hydrocarbons from Canada, on which an additional duty of 10% will be levied; furthermore, an additional tariff of 10% has been established on Chinese goods imported into the United States.

Moreover, for goods imported from Canada, China, and Mexico, the de minimis exemption, a provision that particularly benefits e-commerce transactions and allows shipments up to $800 to enter the United States duty-free, will no longer apply.

The United States is considering extending the tariff measures to other countries as well, including some European economies.

Canada, Mexico, and China are considering introducing countermeasures. Canadian Prime Minister Justin Trudeau has announced retaliatory measures of 25% on US goods, Mexican President Claudia Sheinbaum has promised a proportionate reaction, and the Chinese Ministry of Commerce has declared that it will file the case against the United States at the World Trade Organization as well as the adoption of corresponding countermeasures.

Possible effects for international trade operators:

• Increased sourcing costs: The introduction or increase of duties imposed on goods to and from these countries could lead to an increase in costs for companies, which could be reflected in the final prices of products;
• Delivery times and logistics: The new measures could affect delivery times, with possible delays in international transport due to initial uncertainty and effects on customs operations;
• Sourcing strategies: Companies may have to change their supply chains, trying to diversify suppliers, or negotiate new conditions to reduce the impact of duties.

 

We are constantly monitoring these developments to ensure you can quickly adapt to any changes. Our team is available to help you navigate these changes.

For any questions or need for clarification, do not hesitate to contact us.

The D.B. Group Team