Update on Steel and Aluminum Tariffs

Even the U.S. Supreme Court can’t slow down the president’s pursuit of tariffs. The White House has modified Section 232 tariffs and launched two large Section 301 reviews.

President Donald Trump on April 2 issued a proclamation modifying Section 232 tariffs on steel, aluminum, copper, and related derivative products, effective April 6.

The proclamation reorganizes covered products into four annexes with varying tariff rates. Annex I-A goods—primarily products composed largely of steel, aluminum, or copper—will face a 50% tariff, while certain aluminum and steel derivatives listed in Annex I-B will be subject to a 25% rate. Annex II removes certain products from Section 232 coverage altogether.

Iron or steel screws, bolts, nuts, and washers under HTS 7318 remain subject to a 50% tariff, while products such as steel or aluminum hinges, mountings, and fittings under HTS 8302 are now subject to a 25% tariff.

Annex III establishes a temporary reduced tariff of 15% through Dec. 31, 2027, after which those products will revert to a 25% rate. Articles listed in Annex III also may have the tariff rate increased to 25% for any trading partners if it is found that imports “have increased in a manner that undermines the objectives of the actions taken to address the national security threats.”

A central change is the application of Section 232 duties to the full customs value of covered imports, rather than only the value of the covered metal content. The proclamation also formally ends the Section 232 steel and aluminum derivative inclusion process, which allowed stakeholders to request that additional downstream products be made subject to existing Section 232 tariffs. As of the proclamation’s release, decisions were still pending on requests from the second round, submitted in September 2025.

USTR Opens Broad Section 301 Reviews

The U.S. Trade Representative office has launched two major sets of Section 301 investigations examining foreign industrial and labor practices. Announced over March 11 and 12 and formally published in the Federal Register on March 17, the actions target both industrial overcapacity and labor abuses across a wide range of U.S. trading partners.

One group of investigations examines whether policies in 16 economies are fueling excess manufacturing capacity that may disadvantage U.S. producers. The countries under review include China, the European Union, Japan, India, Mexico, Thailand, and several others.

USTR plans to evaluate how government interventions—such as subsidies, state-directed financing, market restrictions, or weak enforcement of environmental and labor rules—may be encouraging overproduction. The inquiry spans sectors where global output has expanded rapidly, including steel and aluminum, automotive products, semiconductors, machinery, and clean energy technologies.

A separate set of investigations covers forced labor concerns in roughly 60 economies. USTR will assess whether the use of forced or coerced labor, or weak enforcement of labor standards, constitutes an unreasonable or discriminatory practice affecting U.S. commerce. This review includes countries such as China, the EU, Canada, Mexico, India, Japan, Thailand, and the United Kingdom.

Public comments and requests to testify are due April 15, with hearings beginning May 5. Under Section 301 of the Trade Act of 1974, USTR may impose tariff or nontariff measures if it concludes that foreign policies are unreasonable or discriminatory and harm U.S. commercial interests. It is widely expected that the Section 301 investigations may lead to some imports from certain countries being subject to these new tariffs, which are intended to replace the Section 122 tariffs scheduled to expire at 12:01 a.m. ET on July 24.

Progress Made on U.S.-EU Trade Agreement Framework

The European Parliament has advanced the U.S.-EU trade agreement by approving legislation to implement tariff provisions and establish conditions for the next phase of negotiations.

The March 26 vote, passed by a substantial majority, moves the European Union closer to reducing tariffs on U.S. industrial goods and expanding access for certain agricultural products. U.S. officials called the decision a constructive step toward stabilizing transatlantic trade. However, the agreement remains incomplete and requires further negotiation with EU member states.

Rather than fully endorsing the July 2025 framework, lawmakers used the legislation to adjust the terms of engagement. The text introduces safeguards, including a strengthened suspension mechanism and a sunrise clause that delays EU tariff reductions until the U.S. meets its commitments. A sunset provision would end the arrangement in 2028 unless renewed.

With parliamentary approval, the process now advances to final discussions with EU member states, expected to begin in April.

Trump Releases Budget Request

On April 3, Trump released the fiscal year 2027 discretionary budget request, outlining the administration’s funding priorities for the upcoming fiscal year.

The Department of Labor would receive approximately $9.9 billion in discretionary funding under the request, representing a reduction of about $3.5 billion compared to prior enacted levels.

As included in the FY 2026 budget request, the FY 2027 request includes a proposal to consolidate multiple federal workforce development programs under a single initiative, referred to as “Make America Skilled Again.” The budget proposes approximately $4.4 billion for the consolidated workforce funding structure. Under the proposal, states and localities would receive funding through a unified grant program intended to support workforce training activities, with at least 10% of funds reserved for registered apprenticeship programs.

The proposed consolidation would include Workforce Innovation and Opportunity Act programs serving adults, youth, and dislocated workers, as well as other workforce programs such as YouthBuild, apprenticeship grants, and Wagner-Peyser employment services. The budget also proposes eliminating Job Corps, which previously received approximately $1.7 billion in funding.

For the Department of Education, the budget proposes $76.5 billion in discretionary funding, a decrease of about $2.3 billion overall. The request includes a proposed $10.5 billion increase for the Pell Grant program to address projected shortfalls, while proposing the elimination of Adult Education State Grants (approximately $729 million) and reductions to other postsecondary and workforce-related programs.

The Environmental Protection Agency would see a reduction of roughly $5 billion, including cuts to water infrastructure programs. The Department of Energy proposal includes a reduction of approximately $4.7 billion, including decreases to energy-efficiency and renewable-energy programs. The Small Business Administration would be reduced by about $300 million, including consolidation of entrepreneurial development programs. The Cybersecurity and Infrastructure Security Agency (CISA) would see a proposed reduction of approximately $491 million. The budget also proposes increased funding for defense programs, totaling approximately $1.5 trillion.

EPA Proposes Extending Workplace Chemical Safety Deadlines

The Environmental Protection Agency is proposing to delay key workplace safety requirements for two industrial solvents—perchloroethylene and carbon tetrachloride—under the Toxic Substances Control Act. The agency would push several compliance deadlines to 2027 as it reviews parts of the underlying rules. EPA said its core finding that both chemicals pose risks to workers remains unchanged, and the proposal does not alter the substance of the requirements.

Under the proposed rule, which was published in the Federal Register on March 27, EPA would align compliance deadlines for non-federal facilities with those already applicable to federal agencies and contractors. Specifically, regulated entities would have until:

June 21, 2027, to complete initial inhalation exposure monitoring.
Sept. 20, 2027, to meet exposure limits, establish regulated areas, and implement respiratory protection programs.
Dec. 20, 2027, to fully implement exposure control plans.

The extension would give industry an additional one to two years beyond the original deadlines.

EPA accepted public comments on the proposal through April 27.