Section 232 tariffs exemptions. The administration can continue to impose tariffs under Section 232 of the Trade Expansion Act of 1962, which Trump used heavily in his first term, as well. Products covered by Section 232 steel and aluminum tariffs are exempt from global tariffs implemented under IEEPA (IEEPA tariffs apply to the non-steel, non-aluminum The Section 232 Steel & Aluminum Tariffs now focus less on exclusions and more on inclusion requests. Affected importers Trump administration may impose new Section 232 national security tariffs on key industries after Supreme Court invalidates earlier levies. Trump signed a Proclamation imposing a temporary import duty to address Earlier this year, President Trump restored and strengthened Section 232 tariffs on steel and aluminum, widely celebrated by the American steel and aluminum The US Supreme Court has struck down Trump’s emergency tariffs under IEEPA, but the administration has replaced them with a temporary 15 percent global surcharge under Section 122 while preparing President Donald Trump's "reciprocal" tariffs were deemed unconstitutional by the Supreme Court, but some sector-specific tariffs remain in place. The ruling may also narrow US tariff flexibility ahead of upcoming US–China talks, potentially shifting short-term negotiating leverage. While the Court’s decision strikes down President Trump’s drug trafficking and reciprocal tariffs imposed under IEEPA, questions remain as to how any tariff refunds may be distributed, how the tariff rates Goods that were loaded before 24 February and cleared by 28 February are not affected by the new tariff rate. Will there be additional tariffs in the future? The Trump administration has other powers at its disposal beyond the Section 122 tariff. Despite President Trump's April 2 tariff announcement, US steel and aluminum imports remain largely unaffected due to extended USMCA waivers, while potential copper tariffs remain under investigation Notably, certain tariffs – such as those imposed under Section 232 of the Trade Expansion Act 1962 and Section 301 of the Trade Act 1974 – would remain unaffected by the Court’s decision. During a press conference following the U. Supreme Court's opinion, President Trump ckup plans were in place to replace However, as White Case LLP highlighted in January, the Trump administration has already leveraged Section 232 for 25% tariffs on a limited selection of semiconductors imported into America. A pivot toward expanded Section 232 tariffs could reintroduce sector-specific trade uncertainty, particularly for industrials, chemicals and advanced manufacturing supply chains, while preserving A good already paying a 50% Section 232 tariff on steel does not also pay 15% on top of it. The non-stacking provision prevents Section 232 and Section 122 Section 122 authorizes tariffs for only 150 days (unless extended by Congress), which provides the Administration with a limited-duration mechanism while it evaluates potential actions under Sections In December (with the remainder accounted for by Section 232 tariffs), Canada faced an average effective U. This means keeping separate records of which duties were There will be no more overnight tariff shocks. Products detailed in Annex I and Annex II to the proclamation, which mirrors the exemptions that were already in effect for tariffs imposed pursuant to the International Economic Emergency Powers Act The prospective Section 232 tariffs would be issued separately from these measures. The Supreme Court has ruled against Trump’s use of tariffs, but the president has other methods and authorities available to him that could keep his trade agenda alive. tariffs on steel and aluminum continue to drive up the final costs of aircraft, engines, and components. The Trump administration is weighing new Section 232 national security tariff probes targeting six industries, separate from the recently announced 15% global tariff plan. Authority: Section 122 of the Trade Act. Domestic steel and aluminum prices will continue to reflect the tariff environment, and exemptions, quotas, or Despite the improved policy clarity, the structural cost pressures tied to Section 232 remain. Importantly, the Supreme Court decision did not affect existing Section 232 tariffs, which have not faced serious legal Trump's existing sector-specific tariffs for example were imposed under Section 232 of the Trade Expansion Act, which allows the president to roll out levies over national security risks. But here’s the part that confuses people. Learn refund readiness actions, entry filing risks, and Section 122 scope. ECONOMY AND NATIONAL INTERESTS: Today, President Donald J. Sections 122, 301 and 232 now anchor Additionally, U. tariff of 3. We expect the Trump administration to issue new Section 301 and At this time, the official information we have received still indicates a 10% tariff, although this may change in the near future. Explore Section 122 Tariffs and the Presidential Proclamation addressing international payments issues impacting the US economy. The new tariffs apply at a uniform rate of Despite the improved policy clarity, the structural cost pressures tied to Section 232 remain. 1%—the lowest of all major U. The law gives the U. Other exemptions are on informational materials like books, accompanied baggage, and donations. administration is considering narrowing the scope of reciprocal tariffs planned for April 2. That change affects cost, clearance time, and compliance for any business moving If the part or vehicle is covered under the 232 automotive or parts tariff, the item is exempt from the following tariffs: 232 Aluminum, These changes, available here and effective July 1, 2024, aim to refine the framework under which exclusions from the tariffs on steel and aluminum can be requested, ensuring a fairer On Friday September 5, 2025, the Trump Administration issued an executive order that amended the list of products that are currently exempt from Under the new policy, with 50% aluminum content and USMCA compliance (exempt from reciprocal tariffs), the effective tariff remains 25% with content reduction Question 7: Does the use of a Chapter 98 Code exempt imports from Section 232 tariffs? There has been some confusion with Since March 19, 2018, Commerce has published five interim final rules (IFRs) that established and made various improvements to the Section 232 exclusions process, as well as Thus, the new Section 122 duties do not stack on top of the existing Section 232 duties, operating in a similar fashion as the IEEPA tariffs. of the Trade Act of 1974 or Section 232 of the Trade Expansion Act of 1962. Continuing ongoing section 301 investigations (including those involving Brazil and China). “It is excellent that aircraft, engines, and parts are exempt under Section 122, but The 25 per cent tariff imposed under Section 232 was mitigated by the exemption of parts that are CUSMA-compliant, meaning an effective rate on Canadian-produced autos was 15-20 per cent If Section 122 is later struck down but Section 232 remains in effect, the refund is partial: only the Section 122 portion is recoverable. Key Takeaways → President Trump raised global import tariffs from 10% to 15% following a Supreme Court restriction. In addition, product exemptions previously granted under Section 232 continue to apply. president the authority to impose tariffs to protect American There are a number of exemptions to the new 10% duty, including goods subject to separate import taxes justified on national security grounds — so-called Section 232 tariffs — products such as Section 122 tariff stack on top of “any other duties, taxes, fees, exactions, and charges applicable to such products,” except Section 232 tariffs. Maintaining existing section 232 tariffs and conclude ongoing section 232 investigations. Other exemptions from This advisory affects all regions <br /><br />Stay informed on the new U. These Section 122 tariffs include exemptions for USMCA-qualifying goods from Canada and Mexico, goods covered under Section 232, and certain other goods, and are set to expire on July 24, 2026, The NPRM proposes to exclude merchandise subject to tariffs imposed under Section 232, Section 201, and Section 301 from eligibility for duty-free treatment . Following the Supreme Court’s decision to invalidate IEEPA tariffs, the administration replaced those tariffs with Section 122 tariffs under the Trade Act of 1974. Steel derivative products classified in one of the new HTS classifications subject to Section 232 steel duties on or after March 12, 2025 are exempt Customs and Border Protection (CBP) released a CSMS Bulletin on Section 232 – Extensions Requests, Post-Summary Corrections, and Protests on May 1, 2020. trade partners. 2 begin accepting documentation from importers to establish U. Whether they focused on Section 232 because rate modifications offered greater economic value, or because universal exemptions already covered most product requests, this analysis cannot determine. We are awaiting official guidance from the CBP (Customs and Border Protection), and once this is available, we will update this page. The Section 232 and 301 investigations provide longer-term tariff measures than the quick-to-enact Section 122. Any goods already subject to strategic national security tariffs (Section 232 tariffs). → The administration pivoted to Section 122 authority to address international Trump may shift away from a broad tariff shock and move back to targeted tariff packages: Section 232 (national security tariffs), Section 301 (unfair trade practices), Section 201 (safeguard / sudden import This affects only IEEPA duties—Section 232 (national security), Section 301 (unfair practices), and other tariffs remain unchanged. View our What Every Multinational Should Know About The New Section 122 Tariffs and Preserving IEEPA Refund Rights insight. " The Office of the U. content exemptions from Section 232 tariffs on medium and heavy duty trucks and buses that This measure is separate from the 15% universal tariff already announced by President Trump and is expected to be imposed under the U. Another According to Greer, Trump could also invoke tariffs through Section 232, a statute allowing the president to impose tariffs on countries that threaten national security, or Section 338, which The Commerce Department will on Feb. Confusion surrounds US trade policy as President Donald Trump's 10 per cent global tariff under Section 122 takes effect following the Supreme Court's strike-down of earlier Furthermore, goods subject to Section 232 tariffs will continue to face those tariffs in lieu of the Section 122 tariff, with the caveat that, to the extent a tariff imposed under Section 232 applies to part of an The 10% ‘baseline' tariff on all trading partners (Liberation Day Tariffs) Higher ‘reciprocal' tariffs on dozens of countries Drug trafficking tariffs on Canada, Mexico, and China What remains of the Treasury Secretary Bessent stated that combining Section 122, Section 232, and forthcoming Section 301 tariffs "will result in virtually unchanged tariff revenue in 2026. A Supreme Court tariff ruling has voided some duties on Chinese goods, calling into question the terms of the US-China trade agreement. Exemptions under Section 122 appear largely to mirror those Trump applied previously, according to a statement on the 10% tariff issued by the White House on Friday. Trade Section 232 tariffs on steel, autos remain Other tariffs imposed under a separate authority are unaffected by the Supreme Court’s IEEPA ruling. Many of the exemptions that existed for the IEEPA “reciprocal” tariffs have Goods that qualify for USMCA will be exempt from the Section 122 tariff, as will all goods subject to current or forthcoming Section 232 tariffs, said the Section 122 proclamation. The 10% tariff proclamation took effect on February 24 with exemptions for critical minerals, energy products, USMCA goods, and Section 232 items, while the 15% rate awaits signing After the US Supreme Court struck down Donald Trump’s emergency tariffs, the White House activated alternative trade laws to keep import duties in place. Trade Expansion Act Section 232. S. During his first term as president, Trump offered opportunities for importers to seek exemptions from Section 232 tariffs under certain circumstances. 10% import surcharge, potential increase to 15%, and detailed Section 122 exemptions, including critical minerals, Despite the legal setback for President Trump’s country-specific tariffs, he retains the authority to impose Section 232 tariffs on pharmaceuticals imported to the U. Changes are expected to focus on specific countries rather than sectors. Washington’s Section 232 tariffs on inbound semi‑finished copper products are now fully in effect, hitting global suppliers with 50% duties on items like copper wire, tubes, sheets, and rods. The Section 232 and 301 tariffs will remain in place, he added. After the Supreme Court curtailed key second-term tariffs, the Trump administration is turning to Section 232 to pursue new national security levies. Summary:Administration considering new Section 232 Section 232 (national security) and existing Section 301 tariffs remain unchanged and intact. In his first term, President Trump imposed Section 232 tariffs to protect the American steel and aluminum industries from unfair foreign competition. Country-specific tariffs | Product-specific tariffs | Section 122 tariff exemptions | Tariff The effective rate calculation provides a more nuanced view by accounting for Section 122 exemptions and existing Section 232 sectoral tariffs. Moving forward, there are If viewing on a mobile device, rotate your screen for the best experience. In February 2025, the President set tariffs at 25 percent on both steel and aluminum imports from all countries, eliminating previous exemptions, and subsequently raised those rates further in June The Supreme Court’s tariff ruling resolved the narrow legal question of whether IEEPA confers the power to impose tariffs but created substantial uncertainty for businesses on a host of new issues — While Section 232 and Section 301 tariffs remain in place, The White House has invoked Section 122 of the 1974 Trade Act to introduce a temporary blanket tariff of up to 15%, with defined exemptions. The White House is pursuing investigations under Section 232 (national security) and Section 301 (unfair trade The proclamation supersedes other Section 232 measures and exempts covered products from certain reciprocal and border-related tariffs. Recent reports suggest that the U. US tariffs on Asian economies as of 24 February 2026 Click PROTECTING THE U. A few countries were also able to negotiate national The Supreme Court ruling against the IEEPA tariffs provides immediate relief to US businesses and workers and is a welcome rebuke of President Trump’s overreach of executive authority to The 40% tariff on goods from Brazil and the 25% tariff on goods from India do not stack with section 232 tariffs. Domestic steel and aluminum prices will continue to reflect the tariff environment, and exemptions, quotas, or "Section 232 tariffs imposed at the sector level for national security reasons may hurt some parts of Brazil’s manufacturing and mining sectors. Section 232 is the legislation that Trump has used to impose the bulk of his tariffs targeting specific industry sectors. Products under Annex II of EO 14257 are exempt The tariff is in addition to other duties, taxes, fees, exactions and charges, except it shall not apply in addition to Section 232 tariffs; if Section 232 applies to part of an import, the tariff applies only to the SCOTUS Decision On February 20th, 2026, SCOTUS decided that the President’s use of IEEPA to impose reciprocal tariffs on other countries exceeded his authority under that law and held that the Exemptions: Does not apply to products that comply with the terms of CUSMA, nor does it apply to products that separately face Section 232 sectoral tariffs. CBP implements 10% Section 122 import surcharge effective Feb 24–July 24, 2026, with key exemptions under HTSUS 9903. Trump’s existing sector-specific tariffs for example were imposed under Section 232 of the Trade Expansion Act, which allows the president to roll out levies over national security risks. For steel, aluminum, and copper derivative products, Section 122 IEEPA-based tariffs invalidated; CBP ends collection 2/24/26. The White House quickly dismissed reports that US Section 232 steel import tariffs might be reduced, 12 months after their blanket reapplication by then incoming President Donald Trump. Section 232 tariffs against Canada disrupt North American steel trade, cutting imports 68% while raising business costs. 03.
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