As global trade policies continue to shift, importers and manufacturers must stay informed and agile. At Fictiv, we’re dedicated to keeping you informed, helping you optimize your supply chain and maximize your bottom line.
What Is Section 232?
Section 232 of the Trade Expansion Act of 1962 allows the U.S. Government to impose tariffs on imports that are deemed a threat to national security. On March 12, 2025, the U.S. Government enacted a 25% tariff on all aluminum and steel shipments from all countries under this provision, even those with trade agreements. At this time, prototypes made with other materials are not subject to tariffs (due to Chapter 98 duty exemptions)
A Quick Recap of Recent Tariff Changes
Here’s a breakdown of recent tariff updates affecting importers and supply chain management with prototype shipments:
July 7, 2025: Prototypes of all denominations are no longer subject to tariffs, including those containing aluminum or steel.
March 12, 2025: A new Section 232 tariff of 25% was implemented on all aluminum and steel shipments globally, with no exclusions—meaning shipments of prototypes are now subject to duties
March 4, 2025: Another 10% IEEPA tariff was added for all China shipments, but again, prototypes continued to be exempt under Chapter 98.
February 4, 2025: A 10% tariff under the International Emergency Economic Powers Act (IEEPA) was imposed on shipments from China. However, Chapter 98 prototype provisions remained in effect, keeping prototypes duty-free.
What This Means for You
If you are importing aluminum or steel prototypes through Fictiv, this 25% duty now applies to your orders unless they fall under the Chapter 98 prototype provision. As the Importer of Record (IOR), you are responsible for ensuring duties and compliance are properly managed.
There are two primary paths forward for your commercial aluminum and steel orders:
1. Duties Quoted & Prepaid Through Fictiv
We may provide a quote that includes the additional 25% tariff, and Fictiv will prepay the duty on your behalf.
2. You Act as the Importer of Record
Under Incoterms like EXW (Ex Works) or DAP (Delivered at Place), you, the customer, are responsible for paying the duty at the time of import.
Don’t Forget: Customs Bonds & Brokers
For high-value imports over $2,500, you may need to secure a Customs Bond, which acts as a financial guarantee to the U.S. Customs and Border Protection (CBP). This bond covers duties, taxes, and fees, and may be required whether you’re using a Single Entry Bond or a Continuous Bond—depending on your shipment frequency and value.
If you’re unfamiliar with customs procedures, working with a customs broker can simplify the process and help you avoid compliance issues or delays.
Fictiv’s Commitment to You
We understand these changes can create unexpected costs and confusion.
We’re here to help you navigate this new landscape with transparency and support. Please don’t hesitate to reach out to your Fictiv account representative or support team with any questions or concerns about how Section 232 tariffs may affect your orders or should you wish to receive a quote that includes prepaid duty.
Stay Informed. Stay Agile.
Tariffs evolve quickly, and staying ahead of the curve is critical. At Fictiv, we’re monitoring these changes closely and will continue to update you as new policies arise.
Let’s work together to minimize disruption and keep your supply chain running smoothly.
2025 Tariff Impact Timeline
| Date | Tariff Type | Applies To | Prototype Duty Status | Tariff Rate |
|---|---|---|---|---|
| Feb 4, 2025 | IEEPA Tariff | Shipments from China | ✅ Chapter 98 Exemption Applies | 10% |
| Mar 4, 2025 | IEEPA Tariff | All shipments from China | ✅ Chapter 98 Exemption Applies | 10% |
| Mar 12, 2025 | Section 232 | All aluminum & steel shipments from all countries | ❌ No Exemptions (incl. Prototypes) | 25% |
| July 7, 2025 | Section 232 | All aluminum & steel shipments from all countries | ✅ Chapter 98 Exemption Reinstated | 25% |
🧾 What You Need to Know
- Prototype Orders: As of July 7, 2025, prototypes of all denominations are no longer subject to 25% duty under Section 232.
- Chapter 98 Relief Reinstated: Section 232 no longer applies to prototypes, only to commercial orders.
- Incoterms Matter:
- EXW / DAP → You’re the Importer of Record
- DDP (if eligible) → Fictiv pays duties upfront
Importer Checklist
- Identify aluminum or steel in your commercial orders
- Understand your Incoterms
- Set up a Customs Bond (Single or Continuous) for high-value imports
- Consider working with a Customs Broker for compliance and duty payment