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Aircraft Parts, aviation, International Trade, Manufacturing

Manufacturing Raw Materials May Be Impacted by +25% Steel and Aluminum Tariffs

The United States has imposed a 25% additional tariff on steel and aluminum, and on goods derived from steel and aluminum. These new tariffs become effective today. This was referenced in our March 7 blog post.

Importers will need to pay these tariffs on the goods that they import, if the goods are subject to the tariffs. The list of goods subject to the new steel and aluminum tariffs is lengthy. For those MARPA members using steel or aluminum in their production process, this could dramatically increase costs.

Past experience suggests that US producers may take advantage of this situation by raising their own prices for domestic steel and aluminum. This is an easier and less risky short-term response for domestic steel and aluminum producers; instead of trying to invest and expand US production. But this means tat the price for these raw materials is likely to rise no matter where your supply source is located, so the community needs to be careful of making commitments based on the pre-existing prices and availability of these raw materials.

When you import affected steel and/or aluminum goods, make sure you properly classify the goods. This means that imports must be characterized under BOTH the base tariff (and that duty must be paid) and the new tariff under category 99 (and that additional 25% duty must also be paid). Pay careful attention to the tariff publications (and this blog) because the Administration has threatened to add additional tariffs as well as hiking existing tariffs.

References

Federal Register: Implementation of Duties on Steel

Federal Register: Implementation of Duties on Aluminum

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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