PRI's Washington, D.C., office continues to gain new clarity on President Trump's tariffs policies, including details on "stacking," in which some tariffs are combined with others. Here's the latest.

How We Got Here

President Trump earlier this month signed a proclamation doubling tariffs on imported steel and aluminum from 25% to 50%. While the move is aimed at boosting domestic metal production, it will have a significant impact on specialty automotive aftermarket businesses that import products that contain steel and aluminum if the product is not subject to the 232 automotive tariffs.

• Click here to see the products covered by the 25% auto parts tariffs that are exempt from the steel and aluminum tariffs.

The U.S. Customs and Border Protection (CBP) recently updated its guidance on tariff "stacking" steel and aluminum imports and provided information on a three-month extension on exclusions from the China 301 tariffs.

CBP Updated Guidance on Tariff Stacking

CBP recently issued updated guidance on the "stacking" of different tariffs on top of one another. The full memo can be found here. Effective June 4, for imported goods that are subject to more of the tariffs listed below, duties are applied in the following order based on these key rules:

1. Section 232 Auto/Auto Parts:

• If the part or vehicle is covered under the 232 automotive or parts tariff, the item is exempt from the following tariffs: 232 Aluminum, 232 Steel, and IEEPA Canada/Mexico.
• However, auto parts that qualify under USMCA are not subject to 232 Auto/Auto Parts or IEEPA tariffs.
   

2. Section 232 Aluminum and Steel:

• If the automotive/auto parts tariff does not apply, determine if the article is subject to aluminum and/or steel tariffs.
• For derivative products, duties are assessed on the value of each metal that's included in the product.
• If applicable, the item is not subject to IEEPA Canada and Mexico tariffs.
• Russia Note: Imports with aluminum, either smelted or cast in Russia, face a 200% Section 232 duty.
   

3. IEEPA Canada and Mexico

• These tariffs only apply if the auto/auto parts, aluminum, and steel tariffs do not.
• USMCA-qualified articles are exempt from IEEPA tariffs.

CBP Updated Guidance on Steel & Aluminum Imports

• As of June 4, products classified in Ch. 73 (Articles of iron or steel) or 76 (Articles of aluminum) will be assessed the 50% duty only on the steel/aluminum content of that product. Previously, the tariff was assessed on the full value of the imported product. 
• CBP also updated additional guidance and updated Chapter 99 subheadings for Section 232 steel and aluminum imports: Aluminum: View here. Steel: View here.

USTR Extends Certain Exclusions from China Section 301 Tariffs

• The Office of the United States Trade Representative (USTR) extended the expiration date for Section 301 exclusions from May 31, 2025, to August 31, 2025. Click here to learn more.

Have a policy question or want to share how tariffs are affecting your business? Contact Juan Mejia, SEMA's senior manager for federal government affairs, at juanm@sema.org.

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