Adjusting Imports of Aluminum and Steel into the United States

6/3/2025

Proclamations

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Action Summary

National Security Concern: Based on multiple reports from the Secretary of Commerce, both steel and aluminum imports (and their derivatives) are deemed to impair U.S. national security by flooding the market with low-priced products that undercut domestic industry competitiveness.
Tariff Increases:
- Previously imposed tariffs of 25% ad valorem on steel and aluminum articles and their derivatives have been raised to 50% ad valorem effective June 4, 2025.
- Import modifications apply to all countries with a special provision for the United Kingdom, where articles will continue at a 25% tariff under the U.S.-UK Economic Prosperity Deal, unless further adjustments are made after July 9, 2025.
Legal and Administrative Basis:
- Actions are executed under Section 232 of the Trade Expansion Act of 1962, the International Emergency Economic Powers Act, Section 301 of Title 3, and Section 604 of the Trade Act of 1974.
- Modifications to the Harmonized Tariff Schedule of the United States (HTSUS) and related administrative procedures are mandated.
Implementation Details:
- The revised tariff measures will apply to goods entered for consumption from 12:01 a.m. EDT on June 4, 2025.
- Adjustments extend to the classification and treatment of articles in U.S. foreign trade zones, with specific rules regarding “privileged foreign status” and “domestic status.”
- Amendments to Executive Order 14289 ensure that no overlapping tariffs are applied to the same article.
Monitoring & Enforcement:
- The Secretary is directed to continuously monitor imports and consult with executive branch officials regarding any further necessary actions.
- U.S. Customs and Border Protection (CBP) is tasked with enforcing strict declaration rules for steel/aluminum content, with significant penalties for noncompliance.
Supersession of Prior Actions: Any earlier proclamations or executive orders inconsistent with these measures are superseded to align policy priorities and ensure the effectiveness of the new tariffs.

Risks & Considerations

The increase in tariffs on steel and aluminum imports to 50 percent ad valorem could lead to higher costs for industries reliant on these materials, potentially affecting research and development projects at Vanderbilt University that require steel and aluminum.
There is a risk of retaliatory trade measures from other countries, which could impact international collaborations and partnerships that Vanderbilt University may have with institutions in affected countries.
The increased tariffs may lead to a rise in the cost of goods and services, which could affect the university’s operational costs, including construction and maintenance of facilities that utilize steel and aluminum.
Vanderbilt University may need to reassess its procurement strategies to mitigate the financial impact of increased tariffs on imported materials.

Impacted Programs

Engineering and Construction Management programs may face challenges due to increased costs of materials, potentially affecting project budgets and timelines.
The Office of International Affairs might need to monitor and address any diplomatic tensions that could affect international student exchanges and collaborations.
Research departments that rely on imported materials for experiments and projects may need to explore alternative sourcing options or adjust project scopes.

Financial Impact

The increased tariffs could lead to higher operational costs for the university, particularly in areas involving construction and maintenance, which may require budget adjustments.
Potential disruptions in international trade could affect funding and grants from international sources, necessitating a review of financial strategies and partnerships.
Vanderbilt University may need to allocate additional resources to manage the financial implications of the tariffs, including potential increases in tuition or fees to offset costs.

Relevance Score: 4 (The proclamation presents high risks involving major transformations in procurement and financial strategies.)

Key Actions

Vanderbilt’s Office of Federal Relations should closely monitor the impact of increased tariffs on steel and aluminum imports, as these changes could affect the cost of materials for university infrastructure projects. Engaging with suppliers to understand potential cost increases and exploring alternative sourcing options may be necessary to mitigate financial impacts.
The Vanderbilt School of Engineering should assess the potential impact of increased tariffs on research projects that rely on steel and aluminum materials. Identifying alternative materials or adjusting project budgets may be required to ensure the continuation of research activities without significant financial strain.
Vanderbilt’s Economic Research Department should conduct studies on the broader economic implications of the tariff increases, particularly how they might affect local and national industries. This research can provide valuable insights for policymakers and contribute to public discourse on trade policies.
The Vanderbilt Law School should explore the legal ramifications of the tariff changes and provide guidance to the university community on compliance with new import regulations. Offering workshops or informational sessions could help ensure that university departments and affiliated organizations understand and adhere to the updated trade policies.

Opportunities

The executive order presents an opportunity for Vanderbilt’s Business School to develop case studies and courses on international trade and tariff policies. By leveraging real-world examples, the school can enhance its curriculum and provide students with a deeper understanding of global economic dynamics.
Vanderbilt can capitalize on the increased focus on national security and trade by hosting conferences or seminars that bring together experts from academia, industry, and government to discuss the implications of trade policies. This could enhance Vanderbilt’s reputation as a leader in economic and policy research.

Relevance Score: 4 (The order necessitates major process changes due to potential impacts on material costs and research projects.)

Average Relevance Score: 4

Timeline for Implementation

June 4, 2025 at 12:01 a.m. EDT – The modifications to the tariffs (increasing rates from 25% to 50% ad valorem) become effective for goods entered for consumption or withdrawn from a warehouse on or after this date.
On or after July 9, 2025 – The Secretary may adjust the applicable duty rates or construct import quotas for articles from the United Kingdom if compliance with the U.S.-UK Economic Prosperity Deal is not met.

The shortest timeline is June 4, 2025, which indicates an urgent implementation requirement.

Relevance Score: 5

Impacted Government Organizations

Department of Commerce: The Secretary of Commerce is central to this proclamation, having conducted investigations on the impact of aluminum and steel imports on U.S. national security and advising the President on tariff adjustments.
U.S. Customs and Border Protection (CBP): CBP is tasked with enforcing the modified tariff measures and ensuring strict compliance with declaration requirements for the imported goods as stipulated in the proclamation.
United States International Trade Commission (USITC): The USITC is consulted alongside CBP to determine necessary modifications to the Harmonized Tariff Schedule of the United States (HTSUS) to implement the tariff changes.

Relevance Score: 2 (A moderate number of key Federal agencies are directly impacted by the order.)

Responsible Officials

Secretary of Commerce – Oversees monitoring of imports, tariff adjustments, and the issuance of regulations and guidance, as well as coordinating with other agencies regarding national security assessments.
U.S. Customs and Border Protection (CBP) – Responsible for issuing authoritative guidance on compliance, administering the tariffs, and enforcing duty declaration requirements.
United States International Trade Commission – Consulted by the Secretary to determine and implement necessary modifications to the Harmonized Tariff Schedule of the United States.

Relevance Score: 5 (This directive impacts high-level Cabinet officials, including the Secretary of Commerce, and involves agency heads with significant authority over national security and trade policy.)