U.S. importers have borne nearly the full cost of the Section 232 tariffs on imports of steel and aluminum goods and the Section 301 tariffs imports from China, according to a new report from the International Trade Commission. The report has sparked further calls for the Biden administration to lower the tariffs, though to date the White House has shown little interest in doing so.

The ITC states that this report provides a retrospective analysis of U.S. trade, production, and prices in (1) the U.S. steel and aluminum industries and downstream industries that intensively consume steel and aluminum and (2) the U.S. industries that produce the products subject to the Section 301 tariffs (but not downstream industries that consume such goods). However, the ITC adds that the report “is not an assessment of the complete, economy-wide impacts of the tariffs under sections 232 and 301 and cannot be used to draw broad conclusions about whether the tariffs under sections 232 and 301 did or did not produce a net benefit for the U.S. economy overall.”

The report finds that the tariffs resulted in a nearly one-to-one increase in prices of U.S. imports. The ITC states that this nearly complete pass-through (meaning that prices received by exporters were largely unaffected and prices paid by U.S. importers increased by the same amount as the tariffs) is unusual but has been similarly found by other recent studies, which conclude that U.S. importers have borne almost the full burden of section 301 tariffs. The ITC also estimates that for every one percent increase in these tariffs, imports from China of affected products have decreased by about two percent in value. The quantity and the magnitude of this response has slowly increased over time, the ITC notes, likely because U.S. importers have adjusted and found new sources.

Other findings in the ITC’s report include the following.

- Section 232 tariffs reduced imports of affected steel products by 24 percent on average, increased the price of steel products in the U.S. by 2.4 percent, and increased U.S. production of steel products by 1.9 percent. U.S. production of steel was $1.3 billion higher in 2021 due to section 232 tariffs.

- Section 232 tariffs reduced imports of affected aluminum products by 31 percent on average, increased the price of aluminum products in the U.S. by 1.6 percent, and increased U.S. production of aluminum products by 3.6 percent. U.S. production of aluminum was $0.9 billion higher in 2021 due to section 232 tariffs.

- The average annual decrease in production values for downstream industries affected by the Section 232 tariffs was $3.4 billion, and production quantities in these industries decreased by up to almost three percent. The most negatively impacted industries included industrial machinery manufacturing; cutlery and hand tool manufacturing; motor vehicle steering, suspension components, and brake systems; other general purpose machinery; agriculture, mining, and construction manufacturing; and other fabricated metal products.

- Section 301 tariffs reduced total imports from China by 13 percent, increased the value of U.S. production by 0.4 percent, and increased the price of U.S. products by 0.2 percent. Compared to other factors such as the COVID-19 pandemic, supply chain disruptions, surges in energy prices, and Russia’s invasion of Ukraine, the estimated impact of these tariffs appears to explain a relatively large portion of the recent changes in import values of affected goods.

- For the five largest affected industries (cut and sew apparel manufacturing, semiconductors and other electronic components, computer equipment, household and institutional furniture and kitchen cabinets, and motor vehicle parts), the Section 301 tariffs increased (1) the price of imports from China by 1.5 to 24.5 percent, (2) the price of U.S.-produced products from 0.6 to 3.7 percent, and (3) average prices in the U.S. from 0.8 to 7.1 percent. The value of imports from China declined by 5.3 to 72.3 percent and the value of U.S. production increased by 1.2 to 7.5 percent.

The Office of the U.S. Trade Representative is continuing to evaluate comments submitted as part of a review of all Section 301 tariffs on imports from China, which could result in changes to those tariffs at some point, and a USTR spokesman said the agency will take the ITC’s
“relevant, but incomplete, findings into account.”

In the meantime, efforts to ameliorate the impact of these tariffs are continuing.

- ST&R is advocating for the renewal of all previously approved exclusions and the creation of a process allowing for new exclusion requests (for more information, please contact

- There are a number of proven and legitimate ways to effectively avoid the tariffs or limit their impact (click here for more information).

- Importers of List 3 and 4A goods from China can still preserve their rights to possible refunds of tariffs paid on such goods by joining an ongoing court case (for more information, or assistance filing a claim, please contact us at

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