A recent Executive Order issued by the White House has realigned the application of overlapping tariff authorities, particularly those related to national security—Section 232— and the International Emergency Economic Powers Act (IEEPA).
Under the revised framework, the Executive Order preserves the current treatment for auto parts. This means that if a product is subject to Section 232 tariffs on autos and auto parts, it will not be subject to Section 232 tariffs on steel and aluminum, nor to IEEPA-related duties imposed on imports from Canada and Mexico targeting synthetic opioids.
However, the most significant change lies in the reassignment of tariff authority. The Order reverses the previous application, resulting in Section 232 steel and aluminum duties being applied before IEEPA tariffs on imports from Canada and Mexico. This shift aims to better align enforcement mechanisms with the original national security rationale behind each measure.
What This Means
- As of June 4, 2025, goods subject to Section 232 tariffs on autos and auto parts will not be subject to Section 232 steel and aluminum tariffs or IEEPA-related fentanyl duties for Canada and Mexico.
- Goods subject to Section 232 steel and aluminum tariffs and IEEPA fentanyl duties for Canada and Mexico will not be subject to Section 232 auto tariffs.
- Executive Order 14289, “Addressing Certain Tariffs on Imported Articles,” as amended by the Proclamation “Adjusting Imports of Aluminum and Steel into the United States,” applies retroactively to entries of merchandise entered for consumption or withdrawn from warehouse for consumption on or after March 4, 2025.
Reach out to Mohawk Global Trade Advisors for expert insight on duty recovery as a result of this change.