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Section 232 – Not All Quotas Are Created Equal

Since March 2018, when President Trump exercised his authority under Section 232 of the Trade Expansion Act of 1962 to impose a 25 percent tariff on steel imports and a 10 percent import on aluminum,...

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CBP Issues Guidance Requiring Reporting of Smelt and Cast Country of Origin...

Customs and Border Protection (CBP) released new guidance following the announcement of new 200% tariffs on Russian aluminum.  CBP’s guidance outlines new reporting requirements for all imports of...

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GAO Report on Section 232 Exclusions Signals Increased Enforcement for Steel...

On July 20, 2023, the U.S. Government Accountability Office (“GAO”) released a report titled, Steel and Aluminum Tariffs: Agencies Should Ensure Section 232 Exclusion Requests are Needed and Duties are...

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New Section 232 Exclusion Proposed Rules Will Force Additional Burden of...

On August 28, 2023, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) proposed new rules to streamline and strengthen the Section 232 Exclusions Process for Steel and Aluminum...

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Section 232: History and the Exclusion Process

Introduction Section 232 of the Trade Expansion Act of 1962 serves as a critical U.S. trade policy tool designed to safeguard national security by regulating imports. The provision grants the...

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Goods Subject to Tariffs May Lose 321 De Minimis Treatment in Proposed...

On January 21, 2025, U.S. Customs and Border Protection (CBP) published a notice of proposed rulemaking that would make goods subject to tariffs under Sections 232, 201, and 301 ineligible for the de...

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Trump Sets Stage for Future Tariffs and Trade Actions

On his first day in office, President Trump rolled out a sprawling set of directives to the heads of numerous government agencies charged with shaping U.S. trade policy.  While stopping short of...

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White House Updates Section 232 Tariffs on Steel, Aluminum

On February 10, 2025, the White House released an executive order (“EO” or “Order”) titled “Adjusting Imports of Steel into the United States”  that reinstates a 25% tariff on imports of steel and...

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Steel Tariffs Doubled: How the Hike Could Reshape Construction Projects at...

To date the Trump Administration has issued multiple proclamations imposing varying rates of import duties on steel and aluminum and certain derivatives, including construction materials. These...

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