We have held off writing on this due to the constant changes in both the situation and the interpretation of the announcements from President Trump.  However, we have been working with a couple of members on specific issues and thought that the time was right to give you an update.  This sets out the situation as we understand it but you are advised to seek specialist advice before making business decisions.

If all this still leaves you confused – you won’t be alone!  Both Karen ([email protected]) and Geoff ([email protected]) can be contacted if you have a query that none of these links have resolved and we will try to help you through the process.

On June 3, 2025, with an effective date of June 4, 2025, President Trump issued a proclamation raising Section 232 tariffs on steel and derivative steel products from 25% to 50% (with the UK alone in remaining at 25% – this relates to where the metal was produced) which will affect members of the MTA Cluster who export to the USA.  More importantly, on the 15th August the US Government increased the scope by a further 400 products See Reuters US hikes steel, aluminum tariffs on imported appliances, railcars, EV parts | Reuters

US Section 232 Tariffs apply are based on the HS classification of the imported product. Initially, these tariffs were only applied to goods under specific steel and aluminium headings.  However, in the recent Executive Orders, additional goods were added known as ‘steel and aluminium derivative products’ on certain types of machinery.

All these goods are listed with a HS code in the Executive Orders to indicate that they are subject to Section 232 steel and aluminium tariffs. Not every product that contains steel or aluminium will be subject to these tariffs – only those falling under HS specifically listed. 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.

https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3e36e5e

The key to all this is whether your products are on the list of those affected by the Section 232 tariffs.  The pdf file attached to this note shows those product codes.  For machine tools, the only product code affected is Machining Centres (8457 10) – this only serves to highlight how random this all is.  Another example affects a code we were working on for a member – their equipment was not on the list but the related code for parts & accessories for that equipment is on the list.

For goods subject to Section 232 tariffs that have both aluminium and steel content you apply the first tariff you ‘hit’ – aluminium takes priority over steel.

  1. First check if goods have a HS subject to Section 232 Aluminium or Steel Updated steelHTSlist 081525.docx
  2. Then look for aluminium content – apply Section 232 Aluminium rates to the aluminium content and IEPPA reciprocal to the rest (including steel content). If you know there is aluminium in your product, but do not know how much, then Section 232 Aluminium applies to the whole value of the product.
  3. The rate is based on the origin of the aluminium including country of extrusion and processing – if aluminium of non-UK origin then Section 232 rate for the origin country applies (not the UK one which is capped at 25% – Rest of World rate is 50%)
  4. If no aluminium, then you check for steel content – apply Section 232 Steel rates to the steel content and IEPPA reciprocal to the rest and origin considerations same as for the aluminium.
  5. For all imports, robust documentation must be maintained to support the declared value of aluminium and steel content, especially for items not wholly made of these metals.

There is no single publicly available place where all the additional duties can be viewed – HTUS only provides a table with MFN duty rate in column 1 and ‘sanctioned’ rate in column 2 (applies to Cuba, North Korea, Belarus etc)

https://hts.usitc.gov/search?query=8479%208995%2099

There are some commercial options such as Flexport’s Tariff Simulator – https://tariffs.flexport.com/?entryDate=2025-08-27&country=CN&value=10000&advanced=true to assess the US tariffs imposed on imports.

Reed Smith’s tracker can be used for easy access to the applicable proclamations/executive orders per category and/or country – https://www.tradecomplianceresourcehub.com/2025/08/25/trump-2-0-tariff-tracker/

For assistance on all the tariffs being imposed on US imports contact the Chartered Institute of Export and International Trade How to navigate US tariffs

US Steel Tariff codes list (15-Aug-2025)Download
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