Understanding Section 232 Tariffs: A Simple Guide to the Stacking Order
Navigating the world of import tariffs can be complex, especially when a single product seems to fall under multiple categories. A common question for importers is: can a product be charged with more than one special tariff? This is often called “tariff stacking.”
When it comes to Section 232 tariffs—which cover goods like steel, aluminum, and auto parts—the rule is simple: only one Section 232 tariff can apply to a single product.
This guide breaks down the official priority order, based on information from the Federal Register, to help you understand which tariff takes precedence.
What is the Section 232 Tariff Stacking Order?
The U.S. government has established a clear hierarchy to prevent multiple Section 232 tariffs from being “stacked” on the same item. The tariff that applies is determined by the product’s primary classification under the Harmonized Tariff Schedule (HTS).
Here is the official priority order for these tariffs as of June 2025.
1. Automotive and Auto Parts Tariffs
Top Priority: If a product is classified as an automobile or an auto part subject to Section 232 tariffs, this tariff is the only one that applies. It will not also be charged with Section 232 tariffs for steel, aluminum, or lumber.
2. Steel and Aluminum Tariffs
Second Priority: If the product is not an auto part but is classified as steel or aluminum, it will be subject to the relevant Section 232 steel or aluminum tariff. The specific tariff is based on its official HTS code. Other special tariffs like those for lumber or under IEEPA will not be applied.
3. Lumber and Timber Tariffs
Third Priority: If an imported good is primarily classified as timber, lumber, or a related wood derivative, it falls under the Section 232 lumber tariff. This tariff is exclusive, meaning no other Section 232 or IEEPA tariffs will be added.
4. IEEPA and Other Tariffs
Lowest Priority: Tariffs related to the International Emergency Economic Powers Act (IEEPA) or other specific actions (e.g., country-specific tariffs) only apply if the product is not already covered by the auto, steel, or lumber tariffs listed above.
The Golden Rule: HTS Classification is Key
The most important factor in this entire process is the product’s official Harmonized Tariff Schedule (HTS) classification. This code is the definitive identifier for a product in international trade. Whichever Section 232 action specifically covers the goods based on their HTS code is the one that applies. All others are excluded.
Example in Action
Imagine an imported item is constructed with both specialty steel and a rare type of timber. An importer might worry it could be hit with both the Section 232 steel tariff and the Section 232 lumber tariff.
However, based on the stacking rule, this is not possible. Customs officials will look at the product’s HTS classification. If its primary classification is as a steel product, only the steel tariff will be imposed. The lumber tariff will not be stacked on top.
What About Other Duties?
It’s important to note that this “no stacking” rule applies specifically among Section 232 and IEEPA tariffs. Your products will still be subject to all other regular duties.
This includes:
- Most-Favored-Nation (MFN) rates
- Section 301 tariffs
- Antidumping and Countervailing Duties (AD/CVD)
These duties are assessed separately and will be applied in addition to the single applicable Section 232 tariff.
For more detailed information, you can refer to the official document: Addressing Certain Tariffs on Imported Articles.