Skip to navigationSkip to main contentSkip to right columnADVERTISEMENTAntone GonsalvesTue, June 23, 2026 at 12:42 PM GMT+2 4 min readThis story was originally published on Supply Chain Dive. To receive daily news and insights, subscribe to our free daily Supply Chain Dive newsletter.Steel and aluminum producers seeking to qualify for reduced Section 232 tariffs must navigate an intensive record-keeping process to demonstrate ongoing compliance, trade lawyers said.Last month, the Commerce Department introduced a process for Canada and Mexico steel and aluminum makers that feed the U.S. auto and truck industry's supply chain to cut the current 50% tariff in half. Qualifying for the 25% rate requires producers to commit to building or expanding their primary metal production in the U.S.Metal producers have to commit to specific capacity‑expansion projects and submit extensive certified documentation on those projects, according to a Federal Register document. They must then meet milestones set and monitored by the Commerce Department and provide regular, detailed reports showing how shipments tie back to the approved projects.If the Commerce Department determines the supplier has fallen short of the requirements, the agency can revoke the reduced tariff and require full payment. Hence, ongoing documentation and traceability are critical to proving continued compliance, trade lawyers told Supply Chain Dive.Meticulous record-keeping is essential because the program is in its early stages and still needs to be fleshed out, Daniel Pickard, international trade and national security practice lead at Buchanan Ingersoll & Rooney, said."There's obviously going to be a significant amount of discretion at the Department of Commerce in regard to the implementation of this," Pickard said.Qualifying facilitiesThe Commerce Department does not define the types of facilities producers must build or expand to qualify for the tariff reduction. However, eligible facilities could include mills, smelters, electric arc furnaces used to melt scrap steel or casting lines that shape molten metal into semi-finished products, according to Micah Burbanks-Ivey, an associate in Holland & Knight's public policy and regulation group."Suppliers should expect the government to evaluate milestones the same way lenders’ investment and project managers would evaluate whether a major industrial project is progressing."Micah Burbanks-IveyAssociate in Holland & Knight’s public policy and regulation groupCompanies can also use qualifying production in Canada and Mexico, Burbanks-Ivey said, noting those with integrated supply chains across the two countries and the U.S. have a strong opportunity to lower tariffs.Terms and Privacy PolicyPrivacy & Cookie SettingsMore Info