Adjusting Imports of Steel into The United States – Part 1

February 10, 2025

Action Summary

  • National Security Threat: The investigation under Section 232 determined that the scale and circumstances of imported steel articles threaten U.S. national security.
  • Tariff Impositions and Adjustments: A 25% ad valorem tariff was originally imposed under Proclamation 9705. Adjustments include applying tariffs to additional derivative steel articles as detailed in Annex I, with specific conditions for products processed in the United States.
  • Alternative Agreements Reviewed: Proclamations with Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, and the United Kingdom have been deemed ineffective in preventing excessive steel imports and preserving domestic capacity.
  • Termination of Agreements: Effective March 12, 2025, existing alternative arrangements with these countries will terminate, and all imports from these sources will be subject to the additional tariffs of Proclamations 9705 and 9980.
  • Exemption for Ukraine: The temporary exemption for steel articles from Ukraine (and derivative products) is terminated, addressing issues with evasion and unintended benefits to non-Ukrainian producers.
  • Derivative Steel Articles and Evasion: The proclamation addresses the issue of producers evading tariffs by processing steel articles into additional derivative products not initially covered.
  • Product Exclusion Process Termination: The Secretary’s authority to grant exclusions from the additional duties, based on domestic production or quality considerations, is terminated effective immediately to prevent undermining the objectives of the Section 232 measures.
  • Domestic Impact: The tariffs, although initially successful in boosting U.S. steel capacity utilization above 80%, have been undermined by rising imports that depress domestic industry performance and contribute to global overcapacity issues.

Risks & Considerations

  • The imposition of additional tariffs on steel imports from multiple countries could lead to increased costs for industries reliant on steel, potentially affecting construction and manufacturing sectors. This may indirectly impact Vanderbilt University if these sectors are involved in campus development or research projects.
  • There is a risk of retaliatory trade measures from affected countries, which could impact international collaborations and partnerships that Vanderbilt University may have with institutions in these countries.
  • The termination of product exclusions and the imposition of tariffs on derivative steel articles could lead to supply chain disruptions, affecting research projects or infrastructure developments that rely on specific steel products.
  • Vanderbilt University may need to consider the potential impact on its procurement processes and budget allocations if the cost of steel and related products increases due to these tariffs.

Impacted Programs

  • Vanderbilt’s Engineering and Construction Management programs may need to adjust their curricula to address the changing landscape of steel imports and tariffs, preparing students for potential challenges in the industry.
  • The Office of International Affairs might need to monitor and manage any potential impacts on international partnerships and collaborations, particularly with institutions in countries affected by the tariffs.
  • Research initiatives that rely on steel or derivative products may face increased costs or delays, necessitating adjustments in project timelines and budgets.

Financial Impact

  • The increased tariffs on steel imports could lead to higher costs for construction and maintenance projects on campus, potentially affecting budget allocations and timelines.
  • Vanderbilt University may need to explore alternative sources or materials for projects that rely heavily on steel, which could involve additional research and development costs.
  • There may be opportunities for Vanderbilt to engage in research on alternative materials or methods to mitigate the impact of these tariffs, potentially attracting funding from government or industry partners.

Relevance Score: 3 (The order presents moderate risks involving compliance or potential impacts on university operations and partnerships.)

Key Actions

  • Vanderbilt’s Office of Federal Relations should monitor changes in trade policies, particularly those affecting steel imports, to assess potential impacts on research funding and collaborations with industries reliant on steel. Understanding these changes can help the university align its strategic initiatives with national security priorities.
  • The Vanderbilt Center for International Business should analyze the implications of increased tariffs on steel imports for global trade relations and economic policies. This analysis can inform the university’s international partnerships and collaborations, ensuring they remain robust amidst changing trade dynamics.
  • Vanderbilt’s Engineering Department should explore opportunities for research and development in alternative materials and technologies that could mitigate the impact of steel import tariffs. By leading innovation in this area, the department can enhance its research profile and attract funding.
  • The Department of Political Science should conduct research on the broader economic and political impacts of the steel tariffs. This research can provide valuable insights into how these policies affect domestic industries and international relations, positioning Vanderbilt as a thought leader in policy analysis.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s Law School to engage in policy analysis and advocacy related to trade law and national security. By providing expert commentary and analysis, the law school can influence policy discussions and enhance its reputation in the field of international trade law.
  • Vanderbilt can capitalize on the focus on national security by developing programs and partnerships that address the challenges posed by global trade dynamics. This could include joint research initiatives, policy workshops, and collaborative projects with government agencies and industry leaders.
  • The emphasis on supporting domestic industries offers an opportunity for Vanderbilt’s Owen Graduate School of Management to engage in research and consulting projects with companies affected by the tariffs. By providing strategic insights and solutions, the school can strengthen its ties with the business community and enhance its impact.

Relevance Score: 3 (The order requires some adjustments to Vanderbilt’s strategic initiatives and research focus to align with national security and trade policy changes.)

Average Relevance Score: 3.4

Timeline for Implementation

  • Immediate: The termination of the product exclusion process is effective immediately.
  • March 12, 2025: The termination of alternative arrangements with Argentina, Australia, Brazil, Canada, EU countries, Japan, Mexico, South Korea, the United Kingdom, and the termination of the temporary exemption for Ukraine, as well as the adjustment of tariffs on steel and derivative steel articles, will take effect.

Relevance Score: 5

Impacted Government Organizations

  • Department of Commerce: The proclamation explicitly directs the Secretary of Commerce to monitor steel imports, report on national security impacts, adjust tariffs, and publish notices in the Federal Register, making the department the primary agency responsible for implementing and overseeing these measures.
  • U.S. Customs and Border Protection (CBP): Although not named directly, CBP is implicitly affected as it will be responsible for enforcing the adjusted tariffs at U.S. ports of entry by ensuring compliance with the duty payments mandated upon importation.

Relevance Score: 1 (A small number of Federal Agencies are directly impacted by the order.)

Responsible Officials

  • Secretary of Commerce – Tasked with monitoring imports of steel articles, publishing notices in the Federal Register regarding tariff adjustments, implementing the termination of product exclusion processes, and providing further data required under the President’s directives.

Relevance Score: 5 (Directs a Cabinet official with broad, strategic responsibilities affecting national security and trade policy.)