Fifty Days of Tariffs
March 25, 2025Comments
Much is being made of the president’s first few months in office, and for good reason. However, under President Trump, if you miss a day a week might go by. In just his first 50 days, he added 20% to the existing tariffs on China; imposed, then lifted, tariffs on Canada and Mexico, and threatened to impose retaliatory tariffs across the globe. Throughout the back and forth, one threat remained: that President Trump would impose tariffs on steel and aluminum, beginning March 12, a step he did take.
Tariffs imposed on steel imports apply globally under this Section 232 national-security action. However, unlike his first term in office, Trump, as of this writing, did not exempt any countries or implement quotas. To the contrary, he ended the exclusion process, which allowed U.S. importers to request a temporary suspension of the tariffs on their imported steel.
Trump is in a far different position than in 2018, when he began imposing restrictions on steel imports under the guise of increasing the 80% domestic-production capacity-utilization rate. Sources in Washington, D.C., indicate that of all of the tariff actions he has taken, Trump is most committed to steel tariffs.
Section 232 of the Trade Expansion Act of 1962 allows the president to adjust imports that threaten national security. In March 2018, Trump first invoked Section 232 to impose a 25% tariff on imported steel and 10% on aluminum, which he now has increased to 25%. Initially he exempted some allies, while others received quotas. The new tariff action applies to imports from all countries, including Canada, Mexico, Japan, Germany, Italy and France.
Even manufacturers that do not import steel must factor the 25% tariff into their sourcing decisions. Immediately following the president’s announcement (on February 10) that he intended to impose tariffs on steel, domestic steel producers began increasing their prices. As one speaker at the recent PMA 2025 Forming our Future event noted, “Of course we would expect domestic steel producers to increase their prices to match the tariff rate.”
Another important consideration: These tariffs are “stackable,” meaning that the March 12 tariff action is in addition to any other duties, tariffs and fees. Countries, including the United States, impose antidumping (AD) and countervailing duties (CVD) that are product- and country-specific if there is a finding of dumping (selling below fair value) (AD) or foreign government subsidies (CVD). They aim to offset the margin of dumping or subsidy advantage. AD/CVD orders often predate and coexist with the broader tariffs, including the March 12th Section 232 action. Unlike Section 232 or 301 (which apply to broad classes of imports regardless of producer), AD/CVD apply only to products from specific countries/company combinations found to be unfairly traded.
The U.S. antidumping order on cold-rolled-steel flat products sets Japan’s dumping margin at 71.35% for all producers, while the same products from China face a 265.7% dumping margin, with an additional CVD subsidy rate of 256.44%. Stainless steel from some German producers faces a 31% AD rate, Italian stainless wire rod at 11%, and from France up to 148% on carbon and alloy-steel cut-to-length plate.
Steel imports from China will include not only the Section 232 tariff and any AD/CVD orders in effect, such as the 256% rate, but also the 20% new tariff—effective March 4 under the International Emergency Economic Powers Act (IEEPA).
Manufacturers must understand that the United States has layered multiple tariff regimes on steel imports: Section 232 national-security tariffs (25%), Section 301 China tariffs (25%), IEEPA emergency tariffs (20% on certain countries) and AD/CVD orders that can range from single- to triple-digit percentages. Hot-rolled, cold-rolled and stainless steel from several of our allies generally face the Section 232 tariffs (and any normal duties), and specific other duties where applicable.
