In our previous communication, we informed you about the February 10, 2025, Executive Order introducing new tariffs on aluminum and steel imports, effective March 12, 2025. We’re now sharing additional details on how these changes impact derivative products and the adjustments required for your commercial invoices to comply with U.S. Customs and Border Protection (CBP) regulations. Additionally, we want to provide the latest updates on tariff changes between the United States, Canada, Mexico, China, and the European Union (EU), which may affect your supply chain. Maersk Customs Services is here to help you navigate these developments and ensure your operations remain compliant and efficient.
- Steel & Aluminum Tariffs
- For aluminum imports, importers must report:
- Primary country of smelt
- Secondary country of smelt
- Country of cast
- For steel imports, importers must report:
- Country where the steel was melted and poured
- Must be separated on the commercial invoice into two distinct lines:
- One line for the steel or aluminum portion of the finished product.
- A separate line for the other materials (e.g., plastic, rubber, or other metal components).
- The additional duties will only apply to the value of the steel or aluminum content, not the entire finished product.
- Review Your Product Classifications to determine if your aluminum or steel derivatives fall under the affected tariff codes.
- Update Your Commercial Invoice Structure to properly list wholly steel/aluminum products and derivative products separately for accurate tariff application.
- Ensure Supplier Compliance by obtaining correct smelting, casting, and pouring origin details from manufacturers.
- Monitor CBP Announcements for further instructions via CBP’s Cargo Systems Messaging Service.
- EU Countermeasures on U.S. Steel and Aluminum Tariffs
- Reimposition of Suspended Countermeasures: On April 1, 2025, the EU will has announced the 2018 and 2020 rebalancing measures that were previously suspended. These measures will apply tariffs on a range of U.S. goods, including boats, bourbon, and motorbikes.
- New Package of Additional Measures: The EU is also preparing a new package of countermeasures targeting approximately €18 billion worth of U.S. goods. These measures will complement the reimposed tariffs and are designed to ensure a proportionate response to the increased scope of U.S. tariffs. The EU is currently consulting with stakeholders to finalize the list of targeted products, which includes industrial goods (e.g., steel, aluminum, textiles, plastics) and agricultural products (e.g., poultry, beef, dairy, nuts).
- U.S. Tariff Update – USMCA Products from Canada & Mexico
- Be sufficiently transformed according to USMCA rules
- Meet product-specific rules of origin outlined in the agreement
- Canada’s Tariff Policy Update
- China's Retaliatory Tariffs on Canada
- 100% tariffs on:
- Rapeseed oil
- Peas
- Oilcakes
- Annex 1 List of goods subject to additional 100% tariff.pdf
- 25% tariffs on:
- Aquatic fish/seafood products
- Pork
- Annex 2 List of goods subject to additional 25% tariff.pdf
The 25% tariff on steel and aluminum imports took effect on March 12, 2025, at 12:01 a.m. Eastern Time.
Derivative products now impacted:
Aluminum Derivatives: Wire, cables, bumper stampings, body stampings, and other fabricated parts. For a complete list of affected products, click here.
Steel Derivatives: Nails, fasteners, vehicle parts, pipes, tubes, and construction materials. For a complete list of affected products, click here.
Foreign Trade Zones (FTZs) Affected: Goods admitted under “privileged foreign status” before March 12, 2025, remain subject to these tariffs.
New Reporting Requirements:
New Invoicing Requirements
To ensure proper tariff assessment and compliance, importers must adjust how products are listed on commercial invoices:
Wholly Steel or Aluminum Products
Products entirely made of steel or aluminum will remain on a single invoice line with the full value of the product assessed at the applicable tariff rate.
Derivative Products Containing Steel or Aluminum
For reference, see this invoice example.
Next Steps
With the 25% on imports of steel, aluminum, and certain products containing steel and aluminum from the European Union (EU) and other trading partners, the EU has launched a series of countermeasures.
The EU’s response includes two key actions:
The EU’s countermeasures are expected to take full effect by mid-April 2025, following consultations with EU Member States and stakeholders.
The United States has removed tariffs on certain Canadian and Mexican imports under the United States-Mexico-Canada Agreement (USMCA) until April 2nd. This change benefits businesses importing qualifying goods from Canada and Mexico.
However, it is crucial to remember that not all products qualify for USMCA benefits simply because they originate or are manufactured in the U.S., Canada, or Mexico. Goods must still:
If you need assistance in verifying your products' eligibility under USMCA, our Maersk’s customs compliance team is available to help ensure compliance and maximize duty savings.
Canada will maintain its Phase 1 tariff measures on select U.S. products effective March 4th but has paused the planned Phase 2 tariffs until April 2nd. This means that while certain U.S. goods remain subject to existing Canadian tariffs, no additional tariff rounds will be implemented on March 25th as originally announced.
We recommend reviewing your imports to assess the impact of these measures. Our team can provide tariff classification assistance and strategic guidance to mitigate cost implications.
In retaliation to Canada's tariffs on Chinese goods, China has announced that, effective March 20, 2025, it will impose:
These measures are in response to Canada's earlier tariffs on Chinese electric vehicles, steel, and aluminum products. Detailed information on China's tariff measures can be found in the official announcement by China's Ministry of Commerce.
We are here to help
Maersk Customs Services is committed to helping you navigate these evolving trade policies. Our Customs Compliance Team can assist with:
- USMCA Eligibility Reviews: Ensuring your products meet the rules of origin.
- Tariff Classification & Duty Analysis: Identifying cost-saving opportunities.
- Trade Compliance Strategy: Mitigating risks and optimizing supply chain efficiency.
- Tariff Classification: Ensuring accurate classification of your goods.
- Invoice Formatting: Adjusting commercial invoices to comply with new tariff requirements.
- Compliance Strategies: Developing tailored strategies to ensure adherence to evolving regulations.
We are here to support you with your logistics needs and will continue to provide customer advisories and updates as the situation develops.
For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com. For inquiries related to Canadian regulations, reach out to compliance.ca.mcsi.nam@maersk.com.
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