Tariffs with a Baltimore angle: Section 232, 301 and IEEPA

Duty rates change. They have changed more often since 2018 than in the thirty years before it, and a rate that is right today can be wrong by the time the vessel docks. This page does not list rates. It explains the three tariff programs that drive most duty questions, in plain terms, and shows how Foreign Trade Zone 74 and bonded storage change the timing for a Baltimore importer. The licensed customs broker partner confirms the rate that applies to your goods on the day it matters.

Three programs, plainly

Section 232

Section 232 of the Trade Expansion Act of 1962 allows tariffs on imports that the Commerce Department finds threaten national security. Steel and aluminum are the best-known cases, and derivative products made from them have been added over time. The product lists, rates and country treatments change by presidential proclamation.

Baltimore angle: the port is the No. 2 US port for imported aluminum, and steel coils are a named breakbulk commodity at Dundalk Marine Terminal. A metals importer in Baltimore meets Section 232 on a routine basis.

Section 301

Section 301 of the Trade Act of 1974 allows the US Trade Representative to respond to another country’s trade practices with tariffs. The largest program covers goods of Chinese origin across several product lists, with exclusions that come and go. Lists, rates and exclusions change by Federal Register notice.

Baltimore angle: containerized consumer goods, parts and components across the 1,113,309 TEU that moved through Seagirt in 2025. Any importer sourcing from China meets Section 301.

IEEPA

The International Emergency Economic Powers Act lets the President regulate imports after declaring a national emergency. Tariffs under IEEPA have been applied broadly by country of origin and have changed often, sometimes within days. They can stack on top of Section 232 and Section 301 duties on the same goods.

Baltimore angle: autos and light trucks, 728,225 units in 2025 and almost $20 billion of value, and farm and construction machinery, where the port ranks No. 1. Country-based tariffs reach every one of those vehicles.

What an FTZ changes, and what it does not

A foreign trade zone does not change the rate. It changes the timing, and it removes duty on goods that leave the country again.

Timing. Goods admitted to an FTZ 74 site pay no duty on admission. Duty is due when they are withdrawn for US consumption. On a steady program that is weeks or months of deferred cash.

Status choice. On admission the importer elects a zone status. Privileged foreign status fixes the classification and rate as of the day of admission. Non-privileged foreign status takes the classification and rate in effect on the day of withdrawal. When rates are rising, privileged status can protect a lower rate on goods already in the zone. When rates may fall, non-privileged status leaves the door open. Some tariff orders restrict which status is available for the goods they cover, so the broker partner confirms it per order.

Re-exports. Goods that leave the zone for export never pay US duty under any of the three programs.

Inverted tariff. For authorized production in the zone, the importer may pay the rate on the finished product rather than on the components. Whether that helps depends on the specific product and the specific orders, which is a broker question.

The FTZ 74 guide has the activation steps. The duty deferral comparison sets the zone beside bonded, drawback and TIB.

What bonded storage changes

A CBP bonded warehouse also defers duty until withdrawal, and goods withdrawn for export pay nothing. Duty on a bonded withdrawal is assessed at the rate in effect on the day of withdrawal. There is no status election and no inverted tariff. For a storage-only program with modest handling, bonded is simpler. For a program with kitting, assembly, high duty or re-exports, the zone does more.

How to plan when the rate is uncertain

1. Classify first. The HTS code decides which programs apply. Get it confirmed by the broker partner before the purchase order ships.
2. Separate the rate from the timing. You cannot control the rate. You can control when it is paid and whether it is paid on re-exports.
3. Model privileged versus non-privileged status. For goods headed into FTZ 74, the broker partner models both against the orders in force.
4. Keep a re-export share visible. If any volume leaves the US, make sure it moves through the zone or under TIB so it never pays.
5. Review quarterly. Tariff orders change. The desk reviews the program with the broker partner each quarter and when an order changes.

A standing caution

Everything on this page is general. Rates, product lists, country treatments and zone-status rules change by proclamation, notice and court decision. Baltimore 3PL is not a customs broker. Customs clearance, classification and duty calculation are coordinated through our licensed customs broker partners, and they confirm what applies to your goods on the day of entry or withdrawal.

How Baltimore 3PL uses this

The desk coordinates FTZ and bonded warehouse partners inside FTZ 74 so a tariff change becomes a timing decision instead of a surprise. Classification and entries run through our licensed customs broker partners, and for a program-level review of sourcing, duty and routing we offer supply chain consulting.

What to send for a quote

• HTS classifications and countries of origin for the main products
• Annual import value and the current duty paid, if known
• Share of goods re-exported and to which countries
• Whether goods are stored, kitted or assembled before sale
• The question you need answered first: timing, status, or where to put the inventory

Send it to the quote desk and you get a plan, with the broker partner’s input, within one business day.