New legal challenge may redefine impact of steel tariffs on marine supply chains
Image courtesy of NMMA
A legal challenge filed in the United States could have implications for how imported components are valued across marine manufacturing supply chains, particularly those containing steel and aluminium.
Illinois-based Express Fasteners has brought a case before the US Court of International Trade, contesting how US Customs and Border Protection (CBP) is applying expanded Section 232 steel and aluminium tariffs introduced under the Trump administration. The company argues that CBP is incorrectly levying tariffs on the full declared value of imported fasteners, rather than limiting duties to the value of the steel or aluminium content alone.
Section 232 tariffs on steel and aluminium were increased to 50 per cent in June 2025 and were intended to apply only to the metal content of covered products. However, the lawsuit claims CBP has adopted a more expansive interpretation in enforcement, issuing Form 29 notices that challenge importers’ valuation methodologies and discourage excluding costs such as machining, fabrication, or labour.
According to the NMMA, the court case could have ramifications for costs, compliance, and planning in 2026. In a statement the NMMA, says: ‘Why this matters for marine manufacturers: many boats, engines, trailers, and components rely on imported fasteners, fittings, and metal-derived parts. How CBP defines ‘steel content’ can directly affect landed costs, pricing decisions, and compliance risk, even for companies that primarily manufacture in the United States.’
The lawsuit also raises process concerns. Express Fasteners alleges CBP relied on informal, unpublished guidance rather than traditional notice-and-comment rulemaking to change how duties are calculated. Trade attorneys say a court ruling could set limits on how far tariffs can extend downstream and establish clearer guardrails for future enforcement.
A ruling is not expected for several months, but the case is already seen as a test of CBP’s discretion under Section 232. In the meantime, importers face ongoing uncertainty, weighing whether to adopt more conservative valuations to minimise enforcement risk or maintain narrower interpretations and potentially face penalties.
NMMA continues to engage policymakers on the real-world impacts of tariffs on downstream manufacturers and US-based jobs. With 95 percent of boats sold in the US made domestically, recreational marine manufacturing depends on predictable trade rules and fair tariff application to remain globally competitive.
