Have Section 232 tariffs applied to Japanese steel since 2018?
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Executive summary
The United States imposed 25% tariffs on most steel imports under Section 232 in March–June 2018 (Presidential Proclamation 9704/9705) [1]. The U.S. subsequently negotiated a tariff-rate quota (TRQ) with Japan allowing 1.25 million metric tons annually to enter free of Section 232 duties beginning April 1, 2022; imports above each quarterly TRQ face the 25% duty [2] [3]. Available sources do not mention every year since 2018 in exhaustive detail, but the record shows both the original 2018 tariffs and later TRQ/alternative arrangements for Japan [1] [2].
1. How the 2018 Section 232 action started and its baseline effect
In March–June 2018 the Trump administration invoked Section 232 of the Trade Expansion Act to impose additional duties on steel (25%) and aluminum (10%) on national-security grounds; Customs began collecting the tariffs in March 2018 [1] [4]. That action was the baseline legal instrument that could subject Japanese steel to the 25% ad valorem duty unless an exemption, exclusion, or alternative arrangement applied [4].
2. Japan’s special arrangement: a tariff‑rate quota, not a blanket exemption
The U.S.-Japan accord announced in February 2022 established a tariff-rate quota (TRQ) for Japanese-origin steel: 1.25 million metric tons annually across 54 product categories. Steel within the TRQ enters without Section 232 duties; steel that exceeds the quota is subject to the 25% over-quota tariff [2] [3]. The TRQ was implemented on a quarterly, first-come-first-served basis and tied to Japan’s 2018–2019 historical exports in allocation methodology [3] [5].
3. Practical effect since 2018 — a mix of duties, exclusions and quota relief
From 2018 through early 2022 Japanese steel faced the Section 232 duties unless an exclusion applied; the Department of Commerce could grant product-specific exclusions and later established General Approved Exclusions (GAEs) for certain HTS numbers [6]. Beginning April 1, 2022, many Japanese steel shipments that fit into the TRQ categories entered the U.S. free of Section 232 duties up to the quota limits; shipments beyond those limits continued to face the 25% tariff [5] [7].
4. How administrations shifted policy and why that matters
Sources show the Biden administration continued the Section 232 framework but negotiated bilateral arrangements (EU, Japan) that modified how duties applied — essentially trading quota access and other commitments for relief from 25% duties within agreed volumes [8] [3]. Doctrinally the 2018 proclamations remained the legal authority; the TRQ and exclusions operated as carve-outs under that authority [4] [2].
5. Subsequent revocations and policy reversals noted in government notices
The Department of Commerce and BIS later signaled that all General Approved Exclusions and country-level alternative arrangements would be revoked effective March 12, 2025, as part of newer proclamations adjusting steel imports [4]. Some legal analyses and trade groups report that, as of early 2025, prior exemptions and TRQs were being eliminated or altered, meaning the treatment of Japanese steel could change from the 2022 arrangement [9] [10]. Available sources do not mention post‑March 12, 2025 operational details for every product and shipment [4].
6. Two competing interpretations in sources
One view in legal/practice notes emphasizes that Japan effectively avoided routine 25% tariffs for allowed volumes through the TRQ starting in 2022, so Japanese steel has not been uniformly subject to Section 232 duties since 2018 [2] [5]. Another thread notes that the underlying 25% tariff remained the default and that exemptions, TRQs and GAEs were temporary or administratively granted; later policy moves in 2025 sought to revoke those reliefs, re‑exposing previously exempted imports to higher duties [4] [9]. Both positions are supported by government notices and law‑firm analyses in the record [2] [9].
7. What this means for importers, policy observers and readers
Between 2018 and 2022 Japanese steel shipments were generally subject to the 25% tariff unless they benefited from narrow product exclusions; from April 1, 2022 through at least 2024 a defined volume of Japanese steel entered duty-free under the TRQ while over‑quota shipments paid 25% [6] [2] [7]. Policymakers and traders must track evolving proclamations and BIS/Commerce guidance because the existence, size and administration of exclusions and TRQs have changed over time and were explicitly targeted for revocation in 2025 notices [4] [9].
Limitations: sources provided outline the 2018 tariffs, the 2022 U.S.–Japan TRQ (1.25 MMT), GAEs and later revocation notices through early 2025; available sources do not offer a line‑by‑line, year‑by‑year import‑level accounting of exactly which Japanese shipments paid Section 232 duties in each calendar year [2] [6].