ADJUSTING IMPORTS OF ALUMINUM INTO THE UNITED STATES
As a U.S. Customs Broker, we’re here to guide you through the latest trade policy shifts affecting aluminum imports. On February 10, 2025, the President signed Proclamation 10895, "Adjusting Imports of Aluminum into the United States," a pivotal policy under Section 232 of the Trade Expansion Act of 1962. This directive, detailed in Federal Register notices on February 17 and March 5, 2025, introduces significant changes effective March 12, 2025. Here’s what you need to know about the transition from February 10 to March 12 and its impact on aluminum imports.
What is Proclamation 10895 and Section 232 Aluminum Duties?
Proclamation 10895 is a presidential action leveraging Section 232 to address national security threats posed by aluminum imports. Signed on February 10, 2025, it raises tariffs and adjusts import rules, with full implementation starting at 12:01 a.m. Eastern Time on March 12, 2025. The period between these dates marks a critical shift in policy.
Key Changes Between February 10 and March 12, 2025
1. End of Alternative Agreements
February 10, 2025:
· Alternative tariff agreements with Argentina, Australia, Canada, Mexico, EU countries, and the UK remain in effect, offering exemptions or quotas instead of the previous 10% tariff.
March 12, 2025:
· These agreements are terminated, subjecting all aluminum and derivative aluminum imports from these countries to a 25% ad valorem tariff, up from 10%, aligning with broader trade measures.
2. Expanded Tariffs on Derivative Aluminum Articles
February 10, 2025:
Tariffs apply mainly to aluminum articles under Chapter 76 of the HTSUS, with derivative articles not yet under the expanded 25% duty scope.
March 12, 2025:
The 25% tariff extends to derivative aluminum articles listed in Annex I, with duties on aluminum content for non-Chapter 76 items, tracked via new HTSUS subheadings (e.g., 9903.85.67–9903.85.70).
3. Product Exclusion Process
February 10, 2025:
The exclusion process allows requests until 11:59 p.m. Eastern Time, with existing exclusions valid.
March 12, 2025:
The process ends, with no new requests accepted after February 10, and all exclusions expire by March 12, removing tariff relief.
4. Importers’ Responsibilities for Aluminum Content Reporting
February 10, 2025:
No requirement to report aluminum content to CBP for derivative articles.
March 12, 2025:
Importers must provide aluminum content details to CBP for derivative articles, effective as soon as practicable, especially for FTZ entries.
5. HTSUS Modifications
February 10, 2025:
The HTSUS reflects pre-Proclamation 10895 classifications.
March 12, 2025:
HTSUS Chapter 99, Subchapter III, is updated with subheadings like 9903.85.67 (for Russian aluminum articles) and 9903.85.68 (for derivative articles), effective at 12:01 a.m.
6. Foreign Trade Zone (FTZ) Treatment
February 10, 2025:
FTZ goods under privileged foreign status are not yet subject to new tariffs.
March 12, 2025:
These goods face a 25% tariff on aluminum content upon consumption entry, with specific subheadings applying.
7. Enforcement and Drawback Eligibility
February 10, 2025:
Standard CBP enforcement and drawback eligibility apply.
March 12, 2025:
CBP prioritizes misclassification reviews with maximum penalties, and the 25% tariff is ineligible for drawback.
Quick Recap: February 10 vs. March 12
Alternative Agreements: In effect until February 10; terminated by March 12 with a 25% tariff.
Derivative Articles: Limited scope expands to include aluminum content by March 12.
Exclusions: Active until February 10; expired by March 12.
Reporting: No requirement until March 12, when aluminum content reporting is mandatory.
HTSUS: Unchanged until March 12, with new subheadings added.
FTZs: No tariffs on pre-admitted goods until March 12.
Enforcement: Standard until March 12, then heightened with no drawback.
Why This Matters
The shift responds to rising aluminum imports (notably from Russia, with a 200% tariff) and global market pressures. Importers must adapt to higher tariffs, new reporting, and updated classifications to avoid penalties. Contact us for support as you navigate this change
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