Analysis
July 24, 2026
Steel, raw materials exempted from finalized forced labor 301 tariffs
Written by Laura Miller
Steel and many steelmaking raw materials have been spared from additional forced labor Section 301 tariffs.
The Trump administration acted on Thursday, July 23, to impose additional tariffs of 10-12.5% on 60 nations for their actions, or lack thereof, to address forced labor practices in their supply chains.
However, an annex list accompanying the announcement includes a long list of items exempted from the new tariffs.
Steel, aluminum, and copper, as well as their derivatives, are exempted as they are already subject to Section 232 duties.
While there was no special carve-out for raw materials in the US Trade Representative’s initial proposal, industry groups and steel companies argued for their exemption. Their petitions were heard, as steelmaking raw materials are also among the exempted items in the final action. This includes pig iron, DRI/HBI, ferrous scrap, met coal, and anthracite coal.
Iron ore pellets did not make the list of exclusions and are therefore subject to the additional 10-12.5% levy.
Brazil, an important source of raw materials, is included on the list of 60 economies subject to the additional tariffs, as are Canada, Mexico, and a host of others.
Industry response
The American Iron and Steel Institute (AISI) said it supports the stepped-up enforcement against imports made with forced labor, arguing the practice violates human rights and distorts markets by allowing abusive producers to undercut US mills.
The Steel Manufacturers Association (SMA) praised President Trump’s Section 301 move, calling it a complement to the Section 232 steel tariffs and saying the combined actions show the administration is prioritizing domestic manufacturing, supply chain security, and American steel jobs.
