Section 232 Valuation in a Gray Area: What Importers Need to Know
Over the past year, the Section 232 tariff landscape for steel and aluminum has shifted rapidly. A series of presidential actions in 2025 significantly expanded the scope of Section 232 steel and aluminum duties while offering limited instruction on how those duties should be assessed. As a result, companies importing steel and aluminum-containing products are facing unclear guidance at a time when CBP scrutiny – and enforcement – is increasing. This lack of clear guidance has led to a lot of importer confusion and to the lawsuit discussed below.
Background on New Steel and Aluminum Tariffs
On February 11, 2025, President Trump issued two Proclamations imposing enhanced import tariffs on steel and aluminum products under Section 232 of the Trade Expansion Act of 1962. While additional Section 232 tariffs had been in place on certain steel and aluminum products since the first Trump Administration in 2018, the orders eliminated certain exemptions from the tariffs, expanded their scope to cover additional products, and increased the tariffs on covered aluminum goods from 10% to 25%.
On February 18, 2025, two Federal Register Notices were published that included lists of “derivative” steel and aluminum products subject to the 25% tariffs on steel and aluminum under Section 232. The Federal Register Notices, which include the specific Harmonized Tariff Schedule of the United States (HTSUS) classifications for the derivative products in Annex 1, are available
