The implementation date for new steel and aluminum tariffs is approaching. The potential impact of the tariffs is far-reaching because products made of those materials include things like metal furniture, structural elements, nuts, bolts, screws, and countless replacement parts.
Noteworthy is that the calculation of the tariffs can be complicated and will require an understanding of several manufacturing details such as many types of material derivatives, the "smelted and cast" nation, and the first and second "melted and poured countries."
More information can be found on these government web pages.
Federal Register :: Adjusting Imports of Aluminum Into the United States
Federal Register :: Adjusting Imports of Steel Into the United States
Here is some additional information for reference:
When Do the Tariffs Go Into Effect?
On March 12, 2025, the tariffs take effect for entries made after 12:01 a.m. (Eastern Time). All product-specific exclusions will also stop working at that point.
How Will Products Including Steel and Non-Steel Items Be Handled by Customs?
Importers of steel-derivative products will be required by U.S. Customs and Border Protection (CBP) to disclose the amount of steel and aluminum used in their production. It seems that the specific tariff amount for derivative items will depend on the quantity of steel and aluminum present rather than the total entry value. Using the aluminum proclamation as an example, the steel and aluminum proclamations express the following in this regard: "Importers of aluminum derivative articles must give CBP any information required to determine the amount of aluminum used in the production of imports covered by this proclamation in order to carry out the requirements in this proclamation." As soon as it is reasonably possible, CBP will publish regulations or advice implementing this obligation.
How Is the Origin Country Ascertained?
The "smelted and cast" or "melted and poured" standards will be applied by the nation of origin for all items made from steel and aluminum derivatives, respectively. This information will be needed to identify the country of origin, and importers will be required to supply it and attest to its accuracy.
Transmodal will continue to provide updates on this and other pending tariff news as it happens.