President Trump Implements Steel and Aluminum Tariffs

Los Angeles, Calif. (June 4, 2025) - On May 30, 2025, President Donald Trump announced to rallygoers in Pennsylvania that his administration would soon double the tariff on imported steel from 25 percent to 50 percent. On June 3, 2025, President Trump issued a Proclamation that formally doubles the tariffs on steel articles and derivative steel articles, as well as doubling the tariffs (to 50 percent) on aluminum articles and derivative aluminum articles.

As was widely anticipated, the Proclamation was issued pursuant to section 232 of the Trade Expansion Act of 1962 (“Section 232”). A President may issue Section 232 tariffs if the Secretary of Commerce finds that there is a threat to U.S. national security, which the former Secretary of Commerce first did in President Trump’s original administration.

The increase in tariffs will take effect with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on June 4, 2025. Key features of the tariffs (which are summarized in this fact sheet) include:

• The new tariffs apply only to steel and aluminum content within various articles. Non-aluminum, non-steel content of aluminum and steel articles and derivatives will be subject to the so-called Liberation Day tariffs imposed on April 2, 2025, which are presently undergoing numerous court challenges. You can read Lewis Brisbois’ summary of those court decisions in our Lewis Brisbois Client Alert dated May 29, 2025. Please note, however, that on June 3, a federal district court that had ruled against the legality of the Liberation Day tariffs stayed its order that would have halted the Liberation Day tariffs, so that in both cases the appellate courts will decide on whether to place a hold on the Liberation Day tariffs.
   
• Tariffs on steel and aluminum imported from the United Kingdon will remain at 25 percent, at least until July 9, 2025, in light of the U.S.-UK Economic Prosperity Deal. You can read Lewis Brisbois’ summary of the UK trade deal in our Lewis Brisbois Client Alert dated May 20, 2025.
   
• President Trump directed U.S. Customs and Border Protection (“CBP”) to issue guidance requiring strict compliance with declaration requirements for steel and aluminum content in imported articles. Failure to comply may lead to monetary penalties, loss of import privileges, and criminal liability.
   
• The Proclamation amends prior Executive Order 14289 (“EO 14289”) to provide that derivative steel and aluminum articles from Canada and Mexico (intended to cover certain auto parts) will no longer have the benefit of EO 14289’s provisions that would avoid “stacking” or cumulative impacts of overlapping tariffs. Instead, these articles will now be fully subject to the new Section 232 50% tariff. 

Key Takeaways

Steel and aluminum tariffs just doubled for almost all countries. Companies importing or relying on imported foreign steel or aluminum should expect immediate impacts on import compliance, disruption of supply chains, and difficulties in contract performance. Legal challenges are expected, but their success remains to be seen. The numerous reversals and exceptions to the various new tariff programs that we are experiencing are presenting complex compliance issues for many businesses.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editors of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Griffen Thorne, Partner

Editors:

Andrew Pidgirsky, Partner and Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice

Jane C. Luxton, Managing Partner - Washington, D.C.