Legal Challenge Could Shape How Steel Tariffs Hit Marine Supply Chains
A new legal challenge to the Trump administration’s expanded steel and aluminum tariffs could affect how U.S. Customs values imported components used across marine manufacturing supply chains.
Last week, Illinois-based Express Fasteners filed suit in the U.S. Court of International Trade, arguing that U.S. Customs and Border Protection improperly applied Section 232 steel and aluminum tariffs to the entire value of imported fasteners, rather than just the value of the steel content itself.
The tariffs, raised to 50 percent in June, were intended to apply only to the steel or aluminum content of covered products. But according to the complaint, CBP has taken a more aggressive enforcement approach, issuing notices – called Form 29 notices – that challenge importers’ value calculations and discourage excluding costs such as machining, fabrication, or labor.
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 Express Fasteners alleges CBP relied on informal, unpublished guidance rather than traditional notice-and-comment rulemaking to change how duties are calculated.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.
What to watch next
A decision from the trade court could take months, but the case is already being viewed as a key test of CBP’s discretion under Section 232. In the meantime, importers face a difficult choice: overestimate tariff exposure to reduce enforcement risk or maintain narrower valuations and risk penalties.
NMMA continues to engage policymakers on the real-world impacts of tariffs on downstream manufacturers and U.S.-based jobs. With 95 percent of boats sold in the U.S. made domestically, recreational marine manufacturing depends on predictable trade rules and fair tariff application to remain globally competitive.
NMMA will monitor this case closely and keep members informed of developments that could affect compliance obligations and cost structures.
For questions, contact the Clay Crabtree, Senior Director of Public Policy for NMMA at [email protected]