A Presidential Proclamation was posted on the White House website late yesterday noting revisions to existing orders. Effective June 4, 2025, at 12:01 a.m. EST, the tariff rate for imports of steel articles and derivative steel articles, and aluminum articles and derivative aluminum articles will increase from 25 percent ad valorem to 50 percent ad valorem. Tariffs on steel and aluminum imports from the United Kingdom will remain at 25%, with possible changes or quotas starting July 9, 2025, depending on the status of the U.S.-UK Economic Prosperity Deal.
Any steel and/or aluminum article or derivative steel or aluminum article, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation, and that was admitted into a U.S. FTZ and granted “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on June 4, 2025, will likewise be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading added by this proclamation.
No drawback shall be available with respect to the duties imposed pursuant to this proclamation.
In addition, also effective as of 12:01 a.m. EST on June 4, 2025, Executive Order 14289, which establishes the stacking order of specific tariffs, has been amended. A revised hierarchy for the application of multiple tariffs has been issued.
New Priority order - Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on June 4, 2025, below is the new priority order of the five presidential actions identified in EO 14289, as amended:
1) 232 Auto/Auto Parts - Proclamation 10908 of March 26, 2025 (Adjusting Imports of Automobiles and Automobile Parts into the United States), as amended;
2) 232 Aluminum - Proclamation 9704 of March 8, 2018 (Adjusting Imports of Aluminum into the United States), as amended;
3) 232 Steel - Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel into the United States), as amended;
4) International Emergency Economic Powers Act (IEEPA) Canada - Executive Order 14193 of February 1, 2025 (Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border), as amended;
5) IEEPA Mexico - Executive Order 14194 of February 1, 2025 (Imposing Duties to Address the Situation at Our Southern Border), as amended.
For articles subject to more than one of the five tariff actions addressed in EO 14289, filers will pay duty in accordance with the prioritization below. “Subject to” means that duty more than 0% is owed under the tariff action. Filers should calculate duties in the following order, with the understanding that 232 Steel and 232 Aluminum may apply to the same article.
1. First, filers should determine if an article is subject to the 232 Auto/Auto Parts tariff. If so, then the article IS NOT subject to the 232 Aluminum, 232 Steel, IEEPA Canada, or IEEPA Mexico tariffs.
o NOTE: Parts of passenger vehicles and light trucks that qualify for preferential treatment under the United States-Mexico-Canada Agreement (USMCA), ARE NOT subject to the 232 Auto/Auto Parts, the IEEPA Canada, or the IEEPA Mexico tariffs.
2. Next (if the article is not subject to the 232 Auto/Auto Parts tariff), filers should determine if an article is subject to the 232 Aluminum and/or 232 Steel tariff. For derivative products subject to both the 232 Aluminum and 232 Steel tariffs, duties will be owed on both the value of the aluminum and steel content of that product.
If the article is subject to the 232 Aluminum and/or 232 Steel tariffs, as well as subject to IEEPA Canada or IEEPA Mexico tariffs, then the article IS NOT subject to the IEEPA Canada or IEEPA Mexico tariffs.
o NOTE: Aluminum and aluminum derivative products from Russia, and imports of such aluminum products from any country containing aluminum smelt or cast in Russia, ARE subject to the corresponding Section 232 duty rate of 200 percent.
o NOTE: Articles that qualify for preferential tariff treatment under USMCA, ARE NOT subject to the IEEPA Canada or IEEPA Mexico tariffs.
An article subject to the tariff actions identified in this guidance are still subject to other applicable duties, taxes, fees, exactions, and charges, such as, but not limited to, those set forth in column 1 or 2 of the HTSUS; duties imposed pursuant to Section 301, as amended; duties imposed pursuant to EO 14195, “Imposing Duties To Address the Synthetic Opioid Supply Chain in the People's Republic of China”, as amended; antidumping and countervailing duties; etc.
The provisions of EO 14289 are retroactive for covered articles entered for consumption, or withdrawn from warehouse for consumption, on or after March 4, 2025, but the new stacking order described above is effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on June 4, 2025. For covered articles that were entered for consumption, or withdrawn from warehouse for consumption, on or after March 4, 2025, and for which the accompanying duty payment included multiple tariff actions listed in EO 14289, importers may request a refund of the duties no longer due pursuant to EO 14289, as amended.
Requests for refunds, following the prioritization above, may be filed starting May 16, 2025, by filing a post summary correction for unliquidated entries or filing a protest under for entries that have liquidated but where the protest period has not expired.
Refunds outside of the scope of EO 14289 are not authorized. For example, no refunds pursuant to EO 14289 are authorized for 232 Autos/Auto Parts since this tariff measure is at the top of the stacking order.
For full details and the official presidential action, refer to the links below:
Presidential Proclamation – Adjusting Imports of Aluminum and Steel