The additional Guidance states that “’Subject to’ means that duty more than 0% is owed under the tariff action.”  This appears to mean that, if a steel or aluminum product is covered by the Section 232 tariff but if the product is excluded from the Section 232 tariffs because of an exclusion that was granted prior to March 12, 2025, the product is not “subject to” the Section 232 tariffs, and the non-stacking rules do not apply.

The Guidance also indicates that importers can request refunds if they paid stacked tariffs on entries on or after March 4, 2025.

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