Adjusting Imports of Steel into The United States – Part 2

February 10, 2025

Presidential Actions

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Action Summary

Legal Authority: Invokes Section 232 of the Trade Expansion Act and Section 604 of the Trade Act to adjust steel imports that threaten national security.
Proclamation Invalidation & Tariff Imposition: Specifies that multiple previous proclamations governing steel articles and derivative products from countries such as South Korea, Argentina, Australia, Brazil, Canada, Mexico, EU members, Japan, the UK, and Ukraine become ineffective as of March 12, 2025, with additional ad valorem tariffs imposed on future imports.
Revised Duty Rates & Effective Dates: Updates duty rates under Proclamations 9705 and 9980 with phased implementation dates and detailed exceptions by country and specific steel article classifications, including separate rates for steel articles and derivative aluminum articles.
HTSUS Modifications: Directs modifications to subchapter III of chapter 99 of the HTSUS with scheduled annexes detailing tariff rate adjustments and clarifying the scope of affected imports.
Import Monitoring & Compliance:
- Mandates that importers provide detailed information on steel content for accurate classification.
- Empowers CBP to enforce proper classification with penalties for misclassification and to ensure collection of tariff revenue.
Process for Including Additional Products: Instructs the Secretary to establish a process within 90 days for adding further derivative steel articles to the tariff list, including handling requests from domestic producers or industry associations.
Revocation of Prior Relief Measures: Revokes existing product exclusion processes and any provisions allowing relief from the additional tariffs, effective immediately and terminating approved exclusions by March 12, 2025.
Regulatory & Administrative Actions:
- Requires revision of the HTSUS to reflect these changes within ten days after March 12, 2025.
- Specifies that duties imposed are non-refundable (no drawback) and that future modifications will be communicated via the Federal Register.

Risks & Considerations

The imposition of additional tariffs on steel and derivative steel articles could lead to increased costs for industries reliant on these materials, potentially affecting research and development projects at Vanderbilt University that utilize steel in their infrastructure or equipment.
There is a risk of strained international relations with countries affected by these tariffs, which could impact Vanderbilt’s international collaborations and partnerships, particularly those involving research and academic exchanges with institutions in the affected countries.
The changes in trade policy may lead to fluctuations in the availability and pricing of steel, which could affect construction and maintenance costs for university facilities, potentially impacting budget allocations and project timelines.
Vanderbilt University may need to reassess its procurement strategies to mitigate the financial impact of increased tariffs on steel and derivative products, ensuring that budgetary constraints do not hinder ongoing and future projects.

Impacted Programs

Vanderbilt’s School of Engineering may face challenges in sourcing materials for research and development projects, necessitating adjustments in project planning and execution.
The Office of International Affairs might need to navigate potential diplomatic tensions arising from the tariffs, ensuring that international collaborations and student exchanges remain unaffected.
Facilities Management could experience increased costs and delays in construction and maintenance projects due to the tariffs, requiring strategic planning to manage resources effectively.
The Business and Finance Office may need to explore alternative funding sources or cost-saving measures to offset the financial impact of the tariffs on university operations.

Financial Impact

The additional tariffs on steel and derivative products could lead to increased operational costs for the university, particularly in areas related to construction, maintenance, and research infrastructure.
Vanderbilt University may need to allocate additional funds to cover the increased costs of materials, potentially affecting other budgetary priorities and initiatives.
There could be opportunities for Vanderbilt to engage in research and policy analysis related to the economic and trade impacts of the tariffs, potentially attracting funding and collaboration with government and industry partners.
The university’s financial planning and procurement strategies may need to be adjusted to account for the volatility in steel prices and availability, ensuring that financial stability is maintained.

Relevance Score: 4 (The proclamation presents a need for potential major changes or transformations in procurement and international collaboration strategies.)

Key Actions

Vanderbilt’s Office of Federal Relations should monitor changes in import tariffs and trade policies, particularly those affecting steel and derivative steel articles, to assess potential impacts on research funding and collaborations that rely on imported materials.
The Department of Economics should conduct an analysis of the potential economic impacts of increased tariffs on steel imports, focusing on how these changes might affect industries and sectors relevant to Vanderbilt’s research and educational programs.
Vanderbilt’s Procurement Office should review and potentially adjust procurement strategies to mitigate the impact of increased tariffs on steel and derivative steel articles, ensuring cost-effective sourcing for university projects and infrastructure.
The School of Engineering should explore alternative materials and technologies that could reduce reliance on imported steel, fostering innovation and resilience in research and development projects.

Opportunities

The executive order presents an opportunity for Vanderbilt’s Law School to engage in policy analysis and advocacy regarding trade regulations and their implications for national security, potentially influencing future legislative and regulatory frameworks.
Vanderbilt can leverage its expertise in international trade and economics to host conferences and workshops that bring together policymakers, industry leaders, and academics to discuss the broader implications of trade policy changes, enhancing the university’s role as a thought leader in this area.
The focus on national security and trade provides an opportunity for Vanderbilt’s Political Science Department to conduct research on the geopolitical implications of trade policies, contributing valuable insights to the academic and policy-making communities.

Relevance Score: 3 (Some adjustments are needed to processes or procedures due to potential impacts on procurement and research activities.)

Average Relevance Score: 3.8

Timeline for Implementation

The proclamation outlines several deadlines for implementation:

March 12, 2025 at 12:01 a.m. ET – Multiple provisions (e.g., certain tariffs and the in-effect status of prior proclamations) become effective.
Within 90 days after the proclamation’s date – The Secretary must establish a process for including additional derivative steel articles under the applicable duties.
Within 60 days after receiving a request – The Secretary is directed to issue a determination on whether to include a derivative steel article when such a request is submitted by a domestic producer or industry association.
Within 10 days after March 12, 2025 – The Secretary, in consultation with the Commissioner of CBP, must revise the HTSUS to conform to the new amendments.

Relevance Score: 5

Impacted Government Organizations

Department of Commerce – Secretary of Commerce: Responsible for monitoring and modifying the Harmonized Tariff Schedule (HTSUS), implementing tariff adjustments, and publishing modifications in the Federal Register.
U.S. Customs and Border Protection (CBP): Tasked with enforcing the changed import classifications and penalty assessments for misclassifications, as well as processing additional information on steel derivative articles.
United States Trade Representative (USTR): Consulted on monitoring the national security impact of the modifications and imports under the proclamation.

Relevance Score: 2 (Three key federal agencies are directly impacted by the directive.)

Responsible Officials

Secretary of Commerce – Tasked with a wide range of actions including revising the Harmonized Tariff Schedule, establishing processes for including additional derivative steel articles, issuing public notifications regarding system readiness for tariff collection, and rescinding prior product exclusion processes.
U.S. Customs and Border Protection (CBP) – Responsible for implementing information requirements from importers, prioritizing reviews of the classification of imported steel articles, assessing penalties for misclassification, and promptly notifying the Secretary about potential evasion of duty payments.
Commissioner of CBP, Security – Consulted by the Secretary in the process of revising the HTSUS and ensuring effective operational measures are in place.
United States Trade Representative – Consulted periodically by the Secretary regarding the national security implications of derivative steel article imports.

Relevance Score: 5 (Directives affect high-level officials including a Cabinet-level official, the Secretary of Commerce, and other key agency heads through consultation and implementation responsibilities.)