[SMM Analysis]US Expands Section 232 Steel and Aluminum Tariff Product Scope (Adds 407 Items, Effective August 18, 2025) (Part 1)

On 15 August 2025 the U.S. Department of Commerce announced that 407 additional derivative products containing steel or aluminum will be brought under the scope of Section 232 tariffs. The measure takes effect at 12:01 p.m. Eastern Time on 18 August 2025. According to the notice, whenever these goods enter the United States—whether as in-transit shipments or already-held inventories—the steel or aluminum content will be subject to a 50 percent ad-valorem tariff, and no exemptions may be requested.

Below is a review of how the Section 232 steel and aluminum tariffs have evolved.

1. Origin & Legal Basis

• “Section 232” refers to Section 232 of the Trade Expansion Act of 1962, which authorizes the U.S. President to restrict imports that threaten national security.

• The provision was originally designed to prevent excessive U.S. dependence on foreign sources for critical raw materials needed for defense and national security.

2. Trump Administration (2017–2020)

• April 2017: The Trump administration instructed the Department of Commerce to launch a Section 232 investigation into steel and aluminum imports.

• March 2018: The investigation concluded that such imports threaten national security. President Trump signed proclamations imposing a 25 percent tariff on steel products and a 10 percent tariff on aluminum products.

• Initial exemptions were granted to Canada, Mexico, the EU, etc., but most were later removed, triggering trade frictions.

• January 2019: Tariffs were extended to certain “derivative products” (e.g., nails, parts of steel articles), broadening the product scope.

3. Biden Administration (2021–2024)

• October 2021: The U.S. and EU reached an agreement to remove EU steel and aluminum tariffs and replace them with a tariff-rate quota (TRQ) system.

• 2022: Similar arrangements were concluded with Japan and the United Kingdom, partially replacing tariffs with quota management.

• From 2023 onward: High tariffs on most Chinese and other non-exempt steel and aluminum products remained in place.

• 4 June 2024: The U.S. raised tariffs on certain steel and aluminum products and their derivatives from 25 percent to 50 percent, citing the need to combat “overcapacity” and safeguard domestic industry.

4. Latest Developments (2025)

• 30 April 2025: The Bureau of Industry and Security (BIS) issued the “Section 232 Inclusion Procedures,” establishing a mechanism for adding new derivative products to the tariff list.

• 15 August 2025 notice (effective 18 August 2025):
  – Adds 407 derivative products that contain steel or aluminum.
  – Imposes a 50 percent ad-valorem tariff on the steel or aluminum content.
  – Applies to goods already in U.S. inventories; no exemption requests allowed.
  – Covers an extremely broad range, from mechanical parts to consumer-goods packaging.

• The next application window for further inclusions will open in September 2025.

Timeline of U.S. Section 232 steel and aluminum tariffs

• 2018: Initial tariffs introduced (25 % on steel, 10 % on aluminum).

• 2019: Derivative products added to the tariff list.

• 2021–2022: Exemption mechanism adjusted (TRQ replaces some tariffs).

• 2024: Tariffs doubled to 50 %.

• 2025: Formal “inclusion procedure” established; 407 additional derivative products added in August.

Overall trend: From basic metals → expanded derivatives → higher tariff rates → institutionalized inclusion mechanism. The objective is not only to protect domestic industries but also reflects an increasingly assertive U.S. trade protectionism.

SMM New Energy Industry Research Department

Cong Wang 021-51666838

Xiaodan Yu 021-20707870

Rui Ma 021-51595780

Disheng Feng 021-51666714

Yujun Liu 021-20707895

Yanlin Lü 021-20707875

Zhicheng Zhou 021-51666711

Haohan Zhang 021-51666752

Zihan Wang 021-51666914

Xiaoxuan Ren 021-20707866

Jie Wang 021-51595902

Yang Xu 021-51666760

Boling Chen 021-51666836