On June 3, 2025, President Trump raised Section 232 duties on aluminum, steel, and derivatives to 50%, removing reciprocal tariff exemptions and revising the priority framework for US import duties. The changes—effective June 4—affect North American trade, especially with Canada and Mexico, and call for immediate importer compliance review.

This outlines key changes under Executive Order 14289, signed on April 29, 2025, which restricts the stacking of certain U.S. trade remedy tariffs—including Section 232 and IEEPA duties—and establishes a hierarchy for their application. The order applies retroactively to entries from March 4, 2025, potentially allowing importers to seek refunds where overlapping tariffs were imposed.

This will provide a brief outline of key developments last week regarding the current delay and potential re-implementation of tariffs on products of Canada and Mexico, imposed under the International Economic Emergency Powers Act (“IEEPA”) and Section 232 (National Security) duties on steel and steel derivative products and aluminum and aluminum derivative products.

President Trump’s new proclamations expand Section 232 tariffs on steel and aluminum, raising rates to 25% and eliminating exemptions. Businesses should assess supply chains, review exclusions, and prepare for broader tariff coverage.

On 22 November 2024, the European Union issued an FAQ providing detailed guidance on the “best efforts” obligations for EU entities. These obligations require EU entities to ensure that activities undertaken by their non-EU subsidiaries do not undermine EU sanctions on Russia.