Steel and Aluminum Tariffs at 39.8%: Compliance Guide for Manufacturers

Steel and aluminum imports into the United States now face a combined effective tariff rate of 39.8%, comprising the 25% Section 232 tariff on steel (10% on aluminum) plus the 10% Section 122 temporary surcharge, plus applicable anti-dumping and countervailing duties that vary by country and product. For certain steel products from countries subject to AD/CVD orders — such as corrosion-resistant steel from China or hot-rolled steel from Brazil — the total duty rate can exceed 200%.

The Section 232 tariffs, originally imposed in 2018 and expanded in 2025 to eliminate country exemptions, require importers to provide detailed documentation of the country where the steel or aluminum was melted and poured. This 'melted and poured' requirement, enforced through CBP's Steel and Aluminum Import Monitoring (AIS) system, means that simply purchasing steel from a non-tariffed country is insufficient — the raw material must have been produced there. Importers who cannot provide adequate documentation face the full Section 232 rate.

The product exclusion process remains available but has become increasingly difficult to navigate. The Commerce Department's Bureau of Industry and Security (BIS) received over 300,000 exclusion requests in 2025, with an approval rate of approximately 35%. Successful exclusion requests typically demonstrate that the specific product is not available from domestic producers in sufficient quantity or quality. The process takes 3-6 months on average, and exclusions are granted for limited quantities and time periods.

For manufacturers who use imported steel and aluminum as inputs, the tariff impact flows through the entire production chain. A domestic appliance manufacturer using imported stainless steel faces higher input costs that must be absorbed, passed through, or mitigated through sourcing changes. The compliance burden is compounded by the need to track tariff exposure at the component level, maintain exclusion documentation, and reconcile duty payments across multiple entry summaries.

Best practices for managing steel and aluminum tariff compliance include: maintaining a centralized database of all steel and aluminum HTS codes used in your supply chain, implementing automated screening for AD/CVD orders by country and product, filing product exclusion requests proactively for critical inputs, and conducting quarterly audits of melted-and-poured documentation. Companies that treat this as a one-time exercise rather than an ongoing process are at significant risk of compliance failures.