Late Friday night, the White House issued a Presidential Proclamation expanding the scope of the Steel and Aluminum tariffs imposed under Section 232. The Proclamation imposes tariffs on products derived from steel and aluminum which have surged since the imposition of the original 25% Steel tariffs and 10% Aluminum tariffs.  However, the Annexes which will list the new products covered under the proclamation, have not been released.  The text of the proclamation only cites the products under the HTS code for Nails.  Here is what we know:

Tariff:  25% for steel derivatives (downstream products), 10% for Aluminum derivatives

Effective Date:  February 8, 2020

Country Exemptions:  Tariffs will be imposed on all countries EXCEPT – Argentina, Australia, Brazil, Canada, Mexico and South Korea.  The imports from exempted countries are to be monitored for surges and tariffs, quotas or voluntary agreements can be imposed by the Secretary of Commerce with concurrence of the USTR.

Criteria for Inclusion:

  1. Steel is on average, 2/3 or more of the total cost of materials of the product
  2. Import volumes began increasing since June 1, 2018, as compared to the previous 2 years
  3. Import volumes exceed 4%

Exclusions:  Commerce is to provide for exceptions for products determined not to be produced in the US, in a sufficient and reasonably available amount or of a satisfactory quality. An exclusion request must be made by a ‘directly affected party located in the US’.  Exclusions which are granted with be retroactive to the date the requested was accepted by Commerce.

AWPA will provide the Annex listing the covered products, as soon as they are available.