June 4th, 2024 – This CBP guidance updates the tariff stacking order under Executive Order 14289, amended by June 3rd, 2025, Proclamation on Aluminum and Steel Imports. Effective June 4th, 2025, a new priority order is in place for applying tariffs on articles subject to multiple trade actions. The order is as follows:
- 232 Auto/Auto Parts
- 232 Aluminum
- 232 Steel
- IEEPA Canada
- IEEPA Mexico
Key rules include:
- If an article is subject to the 232 Auto/Auto Parts tariff, it is not subject to the others.
- USMCA-qualified parts are exempt from 232 Auto/Auto Parts, IEEPA Canada, and IEEPA Mexico tariffs.
- For products with both 232 Aluminum and Steel, duties apply to each metal’s content.
- Articles covered by 232 Aluminum/Steel are not subject to IEEPA tariffs.
- Special 200% duty applies to Russian-origin aluminum and derivatives.
- Filers must report correct Chapter 99 codes, including USMCA exemptions when applicable.
The amended EO applies retroactively to entries from March 4th, 2025, but the new stacking rules apply only to entries on or after June 4th, 2025. Importers may request refunds for excess duties paid on or after March 4th under prior stacking rules, via post summary correction or protest—excluding 232 Auto/Auto Parts, which remain non-refundable.
Read the full CSMS here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3e36e5e?wgt_ref=USDHSCBP_WIDGET_2
Should you have any questions, please contact our Import Compliance team.
