Customs & Duties

US Section 232 Steel & Aluminium Tariffs: What Indian Exporters Need to Know

Section 232 national security tariffs. India has no exemption. Product exclusion process, duty stacking with ADD, downstream exemptions, and strategic options.

By Aaryan Kakani · · 12 min read

Key takeaways

In March 2018, the United States imposed sweeping tariffs on steel and aluminium imports from nearly every country in the world, citing national security concerns. These tariffs (25% on steel and 10% on aluminium) were levied under Section 232 of the Trade Expansion Act of 1962 and remain in full effect today. For Indian exporters of steel and aluminium products, this has meant a permanent cost disadvantage in what was once a growing export market.

Unlike the EU, Japan, and the UK, India has not secured any exemption, quota, or tariff-rate quota (TRQ) arrangement. Every shipment of covered steel and aluminium from India to the US faces the full tariff. For products that are also subject to anti-dumping duties, the combined duty burden can exceed 60%, effectively pricing Indian goods out of the American market.

This guide explains the legal basis for Section 232, what products are covered, how the tariff interacts with other trade remedies, and what strategic options Indian exporters still have. For a broader overview of exporting to the United States, see our complete US export guide.

What Is Section 232?

Section 232 of the Trade Expansion Act of 1962 gives the President of the United States the authority to impose tariffs or quotas on imports that are deemed to threaten national security. The provision was rarely used for decades, but it was invoked in 2018 when the US Department of Commerce conducted an investigation and concluded that steel and aluminium imports were weakening the domestic industrial base to a degree that constituted a national security threat.

The legal mechanism works as follows: the Secretary of Commerce initiates an investigation (either self-initiated or at the request of another department or an industry petition), conducts the investigation within 270 days, and submits a report to the President. If the report finds a national security threat, the President has 90 days to decide on remedial action. Which can include tariffs, quotas, or a combination of both. Crucially, Section 232 actions are taken under presidential authority, not through the US International Trade Commission (ITC), which handles regular anti-dumping and countervailing duty cases.

The national security rationale has been controversial. Critics argue that the US imports steel and aluminium primarily from allied nations, and that the tariffs are protectionist trade measures dressed up as security policy. The WTO has received challenges from multiple countries, including India, but dispute resolution has been slow. In the meantime, the tariffs remain in force and continue to shape global trade flows.

The Tariff Rates and What They Cover

The Section 232 tariffs, as proclaimed by Presidential Proclamation 9705 (steel) and 9704 (aluminium) in March 2018, impose:

  • 25% ad valorem tariff on steel articles. Covering a wide range of steel products including slabs, ingots, blooms, billets, hot-rolled and cold-rolled flat products, plate, sheet, strip, coil, wire rod, bars, rods, angles, shapes, sections, rails, pipes, tubes, fittings, stainless steel products, tool steel, and electrical steel.
  • 10% ad valorem tariff on aluminium articles. Covering unwrought aluminium, aluminium bars, rods, profiles, wire, plates, sheets, strip, foil, tubes, pipes, tube fittings, castings, forgings, and other aluminium products.

The tariffs are applied ad valorem, meaning they are calculated as a percentage of the declared customs value of the goods. They are assessed at the US port of entry and must be paid by the importer of record before the goods clear customs. As an Indian exporter, while you do not pay the tariff directly, your US buyer absorbs the cost. Which means your effective price competitiveness drops by 25% or 10% compared to domestic US suppliers.

MetalTariff RateKey HTS ChaptersEffective Since
Steel25%HTS 72 & 7323 Mar 2018
Aluminium10%HTS 7623 Mar 2018

India's Exposure and Trade Volumes

India is one of the world's largest steel producers (the second largest as of 2025, behind China) and a significant aluminium producer. The US has historically been an important destination for Indian steel and aluminium, though volumes have declined since the 232 tariffs took effect.

Before the tariffs, India's steel and aluminium exports to the US were valued at approximately $2 billion combined annually . Steel accounted for the larger share at roughly .5 billion, with aluminium contributing around $500 million. Key steel products exported included hot-rolled coil, cold-rolled sheet, galvanised steel, stainless steel flat products, steel pipes and tubes, and wire rod. On the aluminium side, plates, sheets, foil, and extrusions were the primary exports.

Post-tariff, Indian steel exports to the US dropped sharply. Industry estimates suggest a decline of 30. 40% in volume terms in the first two years after the tariffs were imposed. Some product categories, particularly those already facing anti-dumping duties, saw near-complete loss of the US market. Indian exporters have partially redirected these volumes to other markets (Southeast Asia, the Middle East, and Europe) but these alternatives often come with lower realisation prices.

Product CategoryPre-232 Annual Export (est.)Section 232 TariffAlso Faces ADD/CVD?
Hot-rolled steel coil/sheet$400-500M25%Yes (some grades)
Cold-rolled steel sheet$200-300M25%Yes
Steel pipes & tubes 50-250M25%Yes (some categories)
Stainless steel flat products 50-200M25%No
Wire rod & bars 00-150M25%Yes (some categories)
Aluminium plates, sheets, foil$300-400M10%No
Aluminium extrusions 00-150M10%No

Why India Has No Exemption (and Who Does)

When the Section 232 tariffs were first imposed, several countries received temporary exemptions while they negotiated alternative arrangements. Over time, some countries secured permanent alternatives. Typically in the form of tariff-rate quotas (TRQs), which allow a fixed volume of imports to enter duty-free, with the 232 tariff applying only to volumes above the quota.

Country/RegionSection 232 StatusArrangement Type
European UnionTRQ in effectDuty-free up to historic volume, 25% above quota
JapanTRQ in effectDuty-free up to negotiated quota
United KingdomTRQ in effectSeparate post-Brexit TRQ arrangement
South KoreaQuota (steel)Annual quota of ~2.63 million tonnes for steel
AustraliaExempt (steel)Full exemption for steel; aluminium under 232
Canada & MexicoExempt (USMCA)Full exemption under USMCA trade agreement
IndiaFull tariffNo exemption, no quota, no TRQ

India has not secured any such arrangement. The reasons are partly structural and partly diplomatic. The US has repeatedly raised concerns about India's own trade barriers (high import tariffs on American goods, restrictive agricultural policies, and data localisation requirements) as obstacles to granting concessions. Negotiations on a broader bilateral trade package have stalled multiple times.

India challenged the Section 232 tariffs at the WTO in 2018 and also imposed retaliatory tariffs on 28 US products (including almonds, apples, and certain steel products). These retaliatory duties remain in place. However, the WTO dispute settlement process has not produced a binding resolution, and both countries have periodically signalled willingness to negotiate without reaching a conclusion.

How Section 232 Stacks on Top of Anti-Dumping Duties

Section 232 tariffs are entirely separate from the US's regular trade remedy framework. Anti-dumping duties (ADD) and countervailing duties (CVD). This means that if an Indian steel product is already subject to an existing anti-dumping order, the 25% Section 232 tariff is applied in addition to the anti-dumping duty. They do not offset or replace each other.

Several Indian steel products currently face anti-dumping orders in the US. These include certain hot-rolled carbon steel flat products, cold-rolled steel flat products, corrosion-resistant steel products (including galvanised steel), and certain welded pipes and tubes. Anti-dumping duty rates for Indian producers typically range from 5% to 30%, depending on the product and the specific producer.

Duty LayerRate (Typical Range)Applied On
Normal customs duty (MFN)0-3%Customs value
Anti-dumping duty (ADD)5-30%Customs value (product-specific)
Countervailing duty (CVD)2-15%Customs value (if applicable)
Section 232 tariff25% (steel) / 10% (aluminium)Customs value

For a concrete example: if an Indian exporter ships hot-rolled steel coil worth ,000 (customs value) to the US, and the product is subject to a 15% anti-dumping duty plus the 25% Section 232 tariff, the US importer pays ,000 + 50 (ADD) + $250 (232) = ,400 . That is a 40% cost increase before the goods even clear US Customs. If a countervailing duty also applies, the total can exceed 50%.

The Product Exclusion Process

The US Bureau of Industry and Security (BIS) at the Department of Commerce administers a product exclusion process that allows specific products to be exempted from the Section 232 tariffs. An exclusion, if granted, means the product can enter the US without paying the 232 duty. Though regular customs duties and any applicable ADD/CVD still apply.

Exclusion requests must be filed by a US entity. Typically the importer, end-user, or a US-based buyer. As an Indian exporter, you cannot file the petition yourself, but you can work with your US customer to prepare and submit it. This is common practice, and many successful exclusion petitions are driven by the foreign supplier providing technical data and product specifications.

StepWhat happensTimeline
1. File petitionUS entity files an exclusion request on the BIS 232 Exclusions Portal, specifying the HTS code, product dimensions, chemistry, annual volume, and reason for exclusionDay 1
2. Public commentThe request is published in the Federal Register. US domestic producers have 30 days to file objections arguing they can supply the product30 days
3. Rebuttal periodThe requester has 14 days to respond to any objections filed by domestic producers14 days
4. BIS reviewBIS evaluates the request, objections, and rebuttals. May request additional informationUp to 90 days from filing
5. DecisionBIS grants or denies the exclusion. If granted, it specifies the product, volume, and validity period (typically one year)Published in Federal Register
6. RenewalExclusions expire after one year. A new petition must be filed to continue the exemptionFile 90 days before expiry

The key grounds for an exclusion are:

  • The product is not produced in the US in a sufficient and reasonably available quantity.
  • The product is not produced in the US in a satisfactory quality (specific chemistry, dimensions, or tolerances that US mills cannot match).
  • There are specific national security considerations that favour granting the exclusion.

Downstream Articles Exemption

Section 232 tariffs apply to steel and aluminium articles. That is, products that are classified under the steel and aluminium chapters of the Harmonized Tariff Schedule (primarily HTS Chapters 72, 73, and 76). They do not apply to finished goods that merely incorporate steel or aluminium as a component or raw material.

This is a critical distinction for Indian exporters who manufacture downstream products. If you use Indian steel to manufacture auto parts, industrial machinery components, construction equipment, consumer appliances, or any other finished good, and the final product is classified under an HTS code outside Chapters 72, 73, and 76, the Section 232 tariff does not apply to your export.

However, there is a grey area. Some products are substantially made of steel or aluminium and are classified under HTS Chapters 72, 73, or 76 despite being "finished" in a commercial sense. Examples include steel fasteners (bolts, nuts, screws classified under HTS 7318), steel chain (HTS 7315), aluminium castings (HTS 7616), and steel structures (HTS 7308). These products are covered by Section 232 even though they are further processed.

Products typically NOT covered by Section 232

  • Auto parts and components (HTS Chapter 87) that use steel or aluminium in their manufacture
  • Industrial machinery and equipment (HTS Chapter 84) incorporating steel frames or aluminium housings
  • Electrical equipment (HTS Chapter 85) with aluminium conductors or steel enclosures
  • Consumer appliances and furniture that contain steel or aluminium components
  • Hand tools and cutlery (HTS Chapter 82). These are classified separately from raw steel

Strategic Options for Indian Exporters

The Section 232 tariffs are unlikely to be removed or reduced for India in the short term. Indian exporters in the steel and aluminium space have several strategic options to consider.

A. Move Up the Value Chain

The most effective long-term strategy is to shift from exporting raw or semi-finished steel and aluminium to exporting value-added manufactured goods. If you currently export hot-rolled coil, consider investing in downstream manufacturing capability to produce auto components, construction hardware, industrial parts, or other finished goods that are classified outside HTS Chapters 72, 73, and 76. These products avoid the Section 232 tariff entirely and often command higher margins.

B. Pursue Product Exclusions

For niche or specialty products where you have a genuine quality or specification advantage over US domestic mills, work with your US buyers to file product exclusion petitions. This is most viable for specialty steel grades (high-strength alloys, specific chemical compositions), specialised aluminium products, and products where US domestic capacity is genuinely limited. The process is slow and requires renewal, but it eliminates the 232 duty for the approved volume.

C. Diversify Export Markets

If the combined duty burden makes the US market unviable for your product, redirect volumes to markets that do not impose similar barriers. The EU (though it has its own safeguard quotas), Southeast Asia, the Middle East, and Africa are all growing steel and aluminium markets. India's free trade agreements with ASEAN, South Korea, and Japan can provide tariff advantages in those markets.

D. Optimise Pricing and Terms

For products that remain competitive even with the 232 tariff, consider absorbing part of the tariff impact through pricing adjustments. This is not ideal, but some Indian exporters have maintained US market share by offering more competitive FOB pricing, extended payment terms, or value-added services (just-in-time delivery, consignment stocking in the US) that justify the total landed cost despite the tariff.

E. Monitor the Trade Landscape

Trade policy can shift. While no India-specific relief is expected soon, broader changes (a new presidential administration, a comprehensive India-US trade deal, or a WTO ruling) could alter the landscape. Stay connected with industry bodies like the Indian Steel Association and FIEO, which track these developments and lobby on behalf of Indian exporters.

Action checklist for Indian steel & aluminium exporters

  • Verify whether your specific product HTS code falls under Section 232 coverage (Chapters 72, 73, or 76)
  • Check if your product also faces anti-dumping or countervailing duties in the US. Calculate the total landed cost including all duty layers
  • Evaluate whether a product exclusion petition is viable for your specific product and specification
  • Assess whether moving to a downstream, value-added product would eliminate the 232 tariff exposure
  • Map alternative export markets and compare the net realisation after duties against US pricing
  • Read the full US export guide for compliance requirements beyond tariffs

Frequently Asked Questions

Does India have an exemption from US Section 232 tariffs on steel and aluminium?

No. India faces the full 25% tariff on steel and 10% on aluminium with no exemption, quota, or tariff-rate quota. Unlike the EU, Japan, UK, South Korea, Canada, and Mexico (which have negotiated TRQs or exemptions) India has not secured any relief. There are no active negotiations as of mid-2026.

Can Indian exporters apply for a Section 232 product exclusion?

Not directly. The petition must be filed by a US entity (the importer or end-user). However, Indian exporters commonly work with their US buyers to prepare and file exclusion requests through the BIS 232 Exclusions Portal. You provide the product specifications and evidence that the product is not available from US mills. BIS reviews within 90 days, and exclusions are valid for one year.

Do Section 232 tariffs apply to finished goods that contain steel or aluminium?

Generally no. The tariffs apply to steel and aluminium articles classified under HTS Chapters 72, 73, and 76. Finished goods like auto parts, machinery, electronics, and appliances that use steel or aluminium as a component are classified under other HTS chapters and are not subject to Section 232. However, products that are substantially steel or aluminium (fasteners, castings, steel structures) may still fall under the covered chapters.

Can Section 232 tariffs stack on top of anti-dumping duties?

Yes. Section 232 tariffs are applied in addition to any existing anti-dumping duties (ADD) and countervailing duties (CVD). Several Indian steel products face both, resulting in combined duty rates that can exceed 50. 70%. The two types of duties serve different legal purposes and are calculated independently on the customs value.

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