At 12:01AM on Wednesday, March 12, 2025, the 25 percent tariffs on steel and aluminum took effect globally on all imports without any country exemptions. The action marks not only return of the full Section 232 steel and aluminum tariffs, but also increases the tariff rate from 10 percent to 25 percent on all aluminum.
The White House did not grant countries exemptions from the tariffs, nor indicated that the Commerce Department would restart the closed exclusion process, which allowed U.S. importers to request a temporary relief from paying the import tariff. Notably, this Section 232 tariff action differs from the previous measures imposed during President Trump’s first term by also cover 167 products made of steel and 123 imports made of aluminum, collectively known as derivatives of steel or aluminum.
The new tariffs cover dozens of goods One Voice members manufacture. One Voice members should identify whether the Harmonized Tariff Schedule (HTS) code assigned to the product they manufacture, or import, is covered by the 25 percent tariff on derivatives. Companies can view the derivatives list for aluminum here: https://www.federalregister.gov/documents/2025/02/18/2025-02832/adjusting-imports-of-aluminum-into-the-united-states and steel, here:https://www.federalregister.gov/documents/2025/02/18/2025-02833/adjusting-imports-of-steel-into-the-united-states
To view all HTS lists to see your code and corresponding description, please see: https://hts.usitc.gov/.
New Steel & Aluminum Tariffs Begin This Week! Contact the President and Congress to Ensure YOUR Steel & Aluminum Downstream Products Are Covered
Manufacturers using steel or aluminum should contact the White House and Congress to warn that imposing tariffs only on steel or aluminum without extending those same tariffs to U.S. products made of those raw materials simply shifts the injury to downstream manufacturers. Now that President Trump has reinstated the steel and aluminum tariffs, call on him and Congress to also place a 25 percent tariff on the imported products you make from those metals. The President has recognized that placing a tariff only on the raw materials and not on the derivative products, has led to more imports of goods containing steel and aluminum.
The new tariffs took effect this week on March 12 at 12:01AM and NOW is the time to contact President Trump to ensure that the downstream steel and aluminum products that you make are not being imported into the U.S. from unfairly lower priced foreign competition.
Click HERE to contact both the White House and your members of Congress to tell President Trump to add your steel and aluminum downstream products to the list of derivatives covered under the 25 percent Section 232 tariffs.
Be sure to include any and all downstream products that you think should be added to the list. The initial current lists of covered steel and aluminum derivatives can be found at the end of the following Federal Register notices (The steel and aluminum in the products on the list are subject to the 25 percent tariff rate starting March 12):
To make your voice heard and ensure your products are added to those lists, click here!
Tariffs on Canada & Mexico Paused Once Again
In a separate trade action from the tariffs on steel and aluminum imports, following the imposition of tariffs on Canada and Mexico on March 4, President Trump suspended the duties two days later. On March 6, President Trump issued an executive order (EO) amending the newly implemented tariffs allowing all goods from the two countries that enter the U.S. duty-free under the U.S.-Mexico-Canada Agreement (USMCA) to continue to do so until April 2, 2025.
On February 1, 2025, President Trump signed EOs imposed a 25 percent tariff on all goods from Mexico and Canada, excluding energy imports from Canada, which are subject to a 10 percent tariff. After engaging in talks with Mexican President Claudia Sheinbaum and Canadian Prime Minister Justin Trudeau, Trump decided on February 3 to delay the implementation of these tariffs until March 4. The tariffs on imports of steel and aluminum from Canada and Mexico are proceeding under a separate trade action.
One Voice Files Comments on Unfair Trade Practices
On March 11, 2025, One Voice filed formal comments with the Office of the United States Trade Representative (USTR) on “Reviewing and Identifying Unfair Trade Practices and Initiating All Necessary Actions to Investigate Harm From Non-Reciprocal Trade Arrangements.”
USTR is undergoing a review of unfair and non-reciprocal trade policies and practices from other countries to recommend remedies of such practices to the President. The agency has undertaken the review following direction in President Trump’s “America First Trade Policy” memo and the “Reciprocal Trade and Tariffs” memo.
In the notice seeking comments USTR asked for information “on a country-by-country basis, to assist the U.S. Trade Representative in reviewing and identifying any unfair trade practices by other countries, and in initiating all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements.”
In the comments filed on March 11, One Voice discussed the various practices China engages in an effort to circumvent U.S. trade laws and duties such as subsides provided to Chinese manufacturers in the form of direct financial aid, tax incentives, and reduced costs for raw materials and manufacturing inputs, as well as transnational subsides provided to Mexican manufacturers.
“The impact of these subsidies is profound,” the comments state “Chinese firms, bolstered by state support, can offer products at lower prices, thereby gaining a considerable market share and undermining the competitiveness of manufacturers in other countries, particularly in the U.S. This financial backing allows Chinese firms to absorb costs and risks that their American counterparts cannot, creating an uneven playing field that distorts the true cost of production and masks the extent of government intervention.”
The USTR review is due to the President on April 1, after which USTR, the Commerce Department and others “shall initiate, pursuant to their respective legal authorities, all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements adopted by any trading partners,” the memo on the president’s reciprocal trade plan says. Following those actions, the agencies will submit to the President a full report on any proposed remedies.
Executive Order Initiating Investigation of Copper Imports Issued
On February 25, 2025, President Trump issued an executive order (EO) initiating an investigation into the potential national security risks of copper imports. The order directs the Secretary of Commerce to commence the investigation under Section 232 of the 1962 Trade Expansion Act.
The investigation will cover all forms of copper imports, including raw mined copper, copper concentrates, refined copper, copper alloys, scrap copper, and derivative products. The Commerce Department will assess factors outlined under Section 232, which include:
- the current and projected demand for copper in United States defense, energy, and critical infrastructure sectors;
- the extent to which domestic production, smelting, refining, and recycling can meet demand;
- the role of foreign supply chains, particularly from major exporters, in meeting United States demand;
- the concentration of United States copper imports from a small number of suppliers and the associated risks;
- the impact of foreign government subsidies, overcapacity, and predatory trade practices on United States industry competitiveness;
- the economic impact of artificially suppressed copper prices due to dumping and state-sponsored overproduction;
- the potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over refined copper supplies;
- the feasibility of increasing domestic copper mining, smelting, and refining capacity to reduce import reliance; and
- the impact of current trade policies on domestic copper production and whether additional measures, including tariffs or quotas, are necessary to protect national security.
The Secretary will report the findings of the investigation to the President by November 22, 2025.
Legal Challenges to Overtime Rule Continue
The Department of Labor has requested an extension in the case in Texas and Plano Chamber of Commerce et al v DOL, challenging the Biden Administration’s overtime rule. On February 26, 2025, the 5th U.S. Circuit Court of Appeals granted the motion giving the DOL until May 6 to file its opening brief.
The rule, which became effective on July 1, 2024, increased the salary threshold for full-time white-collar exemptions to overtime requirements as well as increased the total annual compensation requirement for “highly compensated employees” (HCE). In November and December of 2024, the rule was vacated and set aside by two separate courts in two cases, both finding that the rule exceeded DOL’s authority and was unlawful.
On November 26, 2024, DOL filed a notice of appeal with the 5th U.S. Circuit Court of Appeals in the State of Texas case, the court which upheld the DOL’s salary basis test when determining overtime eligibility. Additionally, DOL filed an appeal in the other case, Flint Ave v DOL, on February 28, 2025. The appeal takes Flint Avenue to the 5th Circuit as well.
The rule in question, titled “Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees,” increased the standard salary level threshold for white-collar exemptions to overtime requirements under the Fair Labor Standards Act (FLSA) to $43,888 per year while the annual compensation threshold for highly compensated employees (HCE) increased to $132,964. Starting January 1, 2025, the standard salary-level threshold was set to further increase to $58,656 per year, and the HCE threshold will rise to $151,164.