New Section 232 steel and aluminum tariffs are set to go into effect on Saturday, February 8, 2020. The specific lists for steel and aluminum derivative products primarily covers nails, staples, car and tractor parts, and electrical wire, all which have been determined to have seen import surges.

Quota countries got exemptions (for steel: Argentina, Australia, Brazil, Canada, Mexico, South Korea; for aluminum: Argentina, Australia, Canada, Mexico), though Commerce and USTR will monitor imports from these countries for surges.

Exclusion Applications Will Accepted, But Any Exclusion Granted Only Will Apply To Your Company’s Products

There will also be an exclusion process with relief retroactive to the date of its submission. The exclusion applications for Section 232 applications are specific to your company and product. Every company has to apply individually for your own products, unlike the Section 301 exclusion application you cannot use an HTS code that has been excluded for another company, nor can they use your exclusion.


The Trump administration expanded its Section 232 steel and aluminum tariffs to cover certain imported nails, staples, electrical wires and some downstream parts that go into automobiles and tractors, among other products. The tariff hike will take effect on Feb. 8. Link to White House proclamation.

The decision comes almost two years after the administration implemented tariffs on imports of foreign raw steel and aluminum that President Donald Trump said threatened the viability of the domestic industries and therefore threatened U.S. national security.

While imports of aluminum and steel have declined since the Trump administration imposed levies, some derivative products “have significantly increased since the imposition of the tariffs and quotas,” according to Trump’s proclamation.

National security concerns regarding trade fall under Section 232 of the Trade Expansion Act. The original 232 decision of 2018 covered raw metal making and did not include downstream parts, which was a complaint among some domestic makers of parts that go into heavy machinery, automobiles, airplanes and other goods, who worried that importers would avoid the tariffs by simply importing value-added products.

If you are impacted by this change, please contact the MBS Trade Team listed below.

Bio Link Denise co-leads the federal practice at Michael Best Strategies with expertise in association and coalition management as well as development of public policy strategies, at both the state and federal level. She was active, on behalf of firm clients, during the recent federal tax reform debate, much as she was during the last major tax reform in 1986. Expertise: Regulatory Law, Tax & Trade, Energy, Environmental, Food, Agriculture, and Telecommunications
Bio Link Prior to joining Michael Best Strategies, Sarah served as regulatory counsel at ASTM International. In this role, she supported the Office of Global Policy and Industry Affairs on legal, legislative, and regulatory matters. She researched, analyzed, and advised on current and emerging federal policy matters that affected diverse industries, including energy, environment, transportation, technology, and trade. Expertise: Manufacturing, Tax and Finance, PAC, Education, Political Giving, and Transportation
Bio Link Anne’s work involves providing strategic planning, policy advice, and representational services to major corporations on federal and state legislative and regulatory issues in the financial services industry, tax and trade, healthcare, infrastructure, and budget policy areas. Expertise: Tax & Finance, Healthcare, Mortgage, and Bond Insurance
Bio Link Alex works with businesses and associations to help them successfully navigate federal legislative, regulatory, and political solutions on a wide variety of issues. As a member of Strategies’ International Trade Practice, Alex helps clients in more than a dozen industries navigate international trade agreements and various U.S. trade actions, supply chain solutions, and customs issues. Expertise: Trade, Tax & Finance, Education, and Manufacturing
Bio Link Patrick has been very active in politics since his time with the Talbot County Democratic Forum, where he volunteered for President Obama’s re-election as a high school student. While in college, he volunteered for Monty Mason for Delegate of District 93 in Williamsburg, VA; served as a campaign strategist for Virginia’s 1st District congressional candidate, Norm Mosher; and interned on the Hill for Senate Majority Leader Harry Reid in 2014. Expertise: Tax, Financial Services, Environment, Agriculture, Blockchain, Cryptocurrency, and Energy
Bio Link Harrison provides intelligence and analysis on legislative and regulatory issues impacting MBS clientele. Harrison manages news distribution for MBS, including in-depth analysis of breaking political news that pertains to our clients. Additionally, Harrison assists clients with issues involving trade, tax, energy, environment, agriculture, labor, and core business issues. Expertise: Government Relations, Legislative Process, Policy Advocacy, Agribusiness, Trade, Tax & Finance, Energy & Environment.