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Ref. :EIC 111/3
EIC 111/3/13
30 April 2025
(Last updated on 4 June 2025)
Dear Sirs,
Further to Commercial Information Circulars (CICs) No. 148/2025, 200/2025, 220/2025, 258/2025 and 311/2025 dated 12 February 2025, 6 March 2025, 12 March 2025, 27 March 2025 and 7 April 2025 respectively on the US’ tariffs on imports of steel and aluminium as well as automobiles and automobile parts, the US President on 29 April 2025 signed an executive order to address certain section 232 tariffs on imported articles to avoid the cumulative effect of overlapping tariffs; and a proclamation to modify the section 232 tariff action on automobiles and automobile parts.
DETAILS
2.Pursuant to section 232 of the Trade Expansion Act of 1962, on 10 February 2025, the US President signed two proclamations to reinstate 25% tariff on steel imports and increase tariffs on aluminium imports to 25% from all countries/economies (unless otherwise specified), with effect from 12 March 2025. On 26 March 2025, the US President signed a proclamation invoking section 232 of the Trade Expansion Act of 1962 to impose a 25% tariff on imports of automobiles and certain automobile parts effective from 3 April 2025 and 3 May 2025 respectively.
3.On 29 April 2025, the US President signed an executive order to address certain section 232 tariffs on imported articles to avoid the cumulative effect of overlapping tariffs. Among others, an article subject to section 232 tariffs in relation to imports of certain automobiles and automobile parts shall not be subject to the specified additional tariffs, including section 232 tariffs in relation to imports of aluminium and steel on that article; besides, an article subject to section 232 tariffs in relation to imports of certain aluminium and derivative aluminium articles shall be subject to additional tariffs in relation to imports of certain steel and derivative steel articles on that article and vice versa, provided the article otherwise satisfies all conditions necessary for application of those additional tariffs.
4.Accordingly, an article that is subject to the specified section 232 duties may still be subject to other applicable duties, taxes, fees, exactions, and charges, such as, but not limited to, those set forth in column 1 of the Harmonized Tariff Schedule of the United States (HTSUS); duties imposed on Mainland products pursuant to section 301 of the Trade Act of 1974, as amended; additional 20% duties on products of China (including products of Hong Kong), as amended; and antidumping and countervailing duties. This executive order shall apply retroactively to all entries of merchandise subject to any applicable tariffs specified and made on or after 4 March 2025. Any refunds will be processed pursuant to applicable laws and US Customs and Border Protection’s standard procedures for such refunds.
5.On 29 April 2025, the US President also signed a proclamation to modify the section 232 tariff action on automobiles and automobile parts. For automobiles assembled in the US, automobile manufacturers shall be eligible to receive an import adjustment offset amount applicable to section 232 duties on automobile parts based on the schedule specified in the proclamation. The automobile manufacturer may apply for an import adjustment offset amount equal to respectively 3.75% and 2.5% of the aggregate Manufacturer’s Suggested Retail Price value of all automobiles assembled in the US from 3 April 2025 through 30 April 2026, and from 1 May 2026 through 30 April 2027.
6.For further details, please refer to the US President’s executive order, presidential proclamation, the White House’s fact sheet, Federal Register (FR) notices and the US Customs and Border Protection (CBP)’s messages:
The US President’s executive order
https://www.whitehouse.gov/presidential-actions/2025/04/addressing-certain-tariffs-on-imported-articles/
Presidential proclamation
https://www.whitehouse.gov/presidential-actions/2025/04/amendments-to-adjusting-imports-of-automobiles-and-automobile-parts-into-the-united-states/
White House’s fact sheet
https://www.whitehouse.gov/fact-sheets/2025/04/fact-sheet-president-donald-j-trump-incentivizes-domestic-automobile-production/
FR notices
https://www.govinfo.gov/content/pkg/FR-2025-05-02/pdf/2025-07835.pdf
https://www.govinfo.gov/content/pkg/FR-2025-05-02/pdf/2025-07833.pdf
https://www.govinfo.gov/content/pkg/FR-2025-05-20/pdf/2025-09066.pdf
US CBP’s Cargo Systems Messaging Service Message - Updated Guidance - Executive Order 14289 Addressing Certain Tariffs on Imported Articles
https://content.govdelivery.com/bulletins/gd/USDHSCBP-3e0a63e?wgt_ref=USDHSCBP_WIDGET_2
US CBP’s Cargo Systems Messaging Service Message - Updated Guidance - Proclamation “Adjusting Imports of Aluminum and Steel in the United States,” Amending Executive Order 14289, “Addressing Certain Tariffs on Imported Articles”
https://content.govdelivery.com/bulletins/gd/USDHSCBP-3e36e5e?wgt_ref=USDHSCBP_WIDGET_2
7.For enquiries concerning the content of this circular, please contact us at telephone number 2398 5405.
Yours faithfully,
(Miss Kwany KOU)
for Director-General of Trade and Industry
Note: While every effort is made to ensure the accuracy of the above information, the Department cannot guarantee this to be so and will not be held liable for any reliance placed on the same.