CUSBA wants to keep you informed on fast-moving developments. CUSBA’s newest Board Member, Dan Ujczo of Thompson Hine, has provided an update. More details are shared below.
Written on March 12, 2025 PM
Since the publication of the announcement regarding the Section 232 Steel and Aluminum tariffs sent out yesterday, additional details regarding the countermeasures to be imposed by the European Union have been released, which will become effective in two phases: (1) on April 1, 2025 relating to the original countermeasures/retaliation imposed during the initial Section 232 tariffs and that have been suspended, followed by (2) additional countermeasures/retaliation to enter into force likely in mid-April. You can access information Commission responds to unjustified US steel and aluminium tariffs with countermeasures and here are the “new” list of EU countermeasures/retaliation.
Canada has announced additional countermeasures/retaliation that will enter into force on March 13. List of products from the United States subject to 25 per cent tariffs effective March 13, 2025 – Canada.ca. This list largely is a subset of the measures Canada planned to impose as second tranche of countermeasures/retaliation for the U.S. imposition of the IEEPA tariffs. Canada has a remission process (aka exclusion process) in place Process for requesting remission of tariffs that apply on certain goods from the U.S. – Canada.ca and CUSBA can be of assistance in connecting you with parties that can assist with those filings.
President Trump has indicated intentions to “respond” to the countermeasures/retaliation. While that remains to be seen, a result of this month’s actions (i.e., IEEPA tariffs and Section 232) is that all roads are leading to the April 2, 2025 implementation of the U.S. trade strategy as outlined in American First Trade Policy Memorandum, including the reciprocal tariff plan. The interim weeks will likely see negotiations between the U.S. and various countries. In North America, it is anticipated that public consultations regarding the USMCA will launch in short order and continental negotiations may occur in that forum.
CUSBA will continue to work with our partners to monitor and report.
Trump Administration Imposes Section 232 Steel and Aluminum 25% Tariffs March 12, 2025; EU and Canada Retaliate
As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2205, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs. Customs and Border Protection (CBP) guidance confirms that “melted and poured”/ “smelted and cast” reporting is due for all steel and aluminum articles and their derivative products. All existing tariff rate quotas and general/country exclusions have been terminated as of March 11, 2025. Currently, there is no process for interested U.S. parties to seek new product exclusion requests, and all currently-in-force product exclusions will end as of their end date or when quotas are reached. These Section 232 tariffs are in addition to any other imposed duties or tariffs, including the recent IEEPA tariffs imposed against China, Mexico and Canada.
Updated CBP guidance can be found on the Cargo Systems Messaging Service (CSMS):
- CSMS # 64384496 – UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products
- CSMS # 64384423 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
- CSMS # 64375535 – Quota Guidance: Proclamation 10896 of February 10, 2025, Adjusting Imports of Steel and Aluminum into the United States
For additional background on these new tariffs on imported steel and aluminum articles and their derivative products from all countries, see Thompson Hine Updates of February 12, 2025 and February 14, 2025.
As expected, Canada and the European Union (EU) responded with countermeasures and retaliatory tariffs. The EU announced a two-step approach: (1) the end of the suspension of existing 2018 and 2020 countermeasures against the United States on April 1, 2025; and (2) a package of new countermeasures on U.S. exports to enter into force by mid-April 2025, following the consultation of EU member states and stakeholders. Canada announced that it will respond with a “dollar-for-dollar” approach with 25% retaliatory tariffs on U.S. goods worth approximately $21 billion. The package of Canadian countermeasures is expected to be announced in the near future. Canada also announced that these U.S. tariffs violate U.S. obligations under both the USMCA and the World Trade Organization (WTO) Agreement and that it will be seeking consultations with the United States as a first step in any dispute settlement under these agreements. Mexico has indicated that it may delay any retaliatory measures until April 2, 2025, when President Trump has indicated the United States will impose separate reciprocal tariffs “to see if we also need to take some actions.”
CUSBA encourages the countries involved to work diligently towards addressing their shared concerns with the borders, to avoid what could be self-destructive actions aimed not at our adversaries, but at long-time friends and allies.
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