The rapidly evolving trade and tariff landscape has significantly impacted how our APPA Members and the pet industry conducts business. We have introduced a new Trade Talks series, that seeks to help inform and answer questions from our community about critical updates in this area. During our October Open Office Hours, we received a question regarding a recent petition to the U.S. Department of Commerce that has brought a critical trade policy, the Section 232 tariffs, directly to the doorstep of every company that relies on canned pet food.
This request, led by the Can Manufacturers Institute (CMI), seeks to close a perceived loophole that could dramatically increase the cost of imported canned goods, including some of the most popular wet pet foods. For members of the American Pet Products Association (APPA), understanding this complex issue is no longer optional, it is a matter of business continuity and strategic sourcing.
The CMI, a national trade association representing U.S. metal can manufacturers, has formally submitted a request to the Department of Commerce asking for filled food cans to be included as "derivative articles" subject to the existing Section 232 steel and aluminum tariffs.
This request is a reaction to the previous imposition of tariffs on raw materials (steel and aluminum) and empty metal cans. The CMI argues that while those earlier tariffs protected domestic raw material producers, they created a glaring vulnerability. Foreign competitors, facing the same tariffs on raw steel or aluminum, simply shifted their operations to manufacture and fill the cans outside of the U.S. and then import the finished product, effectively evading the tariffs on the metal packaging itself.
The CMI points to startling data to support its claim of a grave threat to U.S. can manufacturers and fillers. Imports of canned meat products, which are closely related to pet food components, have surged. For instance, prepared canned meat imports saw a 21% increase from 2017 to 2024, with some specific canned meat prepared meals spiking by a massive 199% by volume over the same period. This trend, the CMI asserts, is "erod[ing] the customer base for U.S. producers of aluminum and steel".
While the CMI request focuses on food cans (including HTSUS codes for canned meats and prepared meals that often mirror pet food ingredients), the threat to the pet industry is immediate and significant should the petition be approved. The canned food segment is a powerhouse in the pet market, making the potential inclusion of these tariffs a business-critical issue for APPA members.
Trade consultant Rebecca Rizzuti, a partner with Progressive Trade Consulting, directly addressed this exposure in a recent trade talk, confirming that the potential inclusion is very much on the industry's radar. She highlighted the mechanism of the risk:
"So, what we're talking about is obviously the packaging of the pet food, right? And so if it's coming in an aluminum or steel cans, the concern is, is that it's going to get pulled into, the derivative tariff of 232."
The most alarming aspect of this proposal is the potential financial shock to the supply chain. If the Department of Commerce approves the CMI’s request and makes it legislation, the cost of imported canned pet food will immediately jump, putting immense pressure on pricing and profit margins.
During APPA’s October Trade Talks Open Office Hours, Rebecca Rizzuti clearly indicated the potential financial hit for APPA Members:
"If you're paying, a dollar today, anticipate you're going to be paying 50% tariff, on 232 for that steel and aluminum can, if pet food gets included."
This kind of increase, applied literally overnight to products already in the supply pipeline or on their way to port , would force companies to either absorb the cost, significantly impacting their balance sheets, or immediately raise retail prices, potentially leading to market disruption.
The inevitable reaction of the industry to a 50% tariff would be to move production away from affected import origins and shift to domestic or tariff-exempt partners, or even switch packaging formats altogether (e.g., from cans to pouches). This massive demand shift could put a strain on existing domestic suppliers, creating an environment where prices for domestic packaging will naturally rise due to simple supply and demand pressures.
As Rebecca Rizzuti points out, simply shifting your supplier list won't be a painless solution:
"You've got to find the people that can supply it to you. And I'm sure demand is weighing heavily on that price because their demand is probably spiking at the same time."
Beyond seeking alternative sourcing solutions, packaging alternatives can be very complicated as well. As Rebecca explained:
“...remember, 50% on steel and aluminum is usually giving you a reprieve from something else like reciprocal tariffs. So, if you get out of steel aluminum, make sure that your reciprocal tariff rate, combined with the new cost of purchasing that packaging, doesn't exceed the 50%, because otherwise you may want to stay where you're at. So it's a lot of costing.”
As we frequently discuss in our Trade Talk series, the trade landscape is evolving every day. There are typically no quick and easy shortcuts, and it is important that businesses are paying attention and reaching out for help when needed. This situation is a stark reminder of how quickly and significantly trade policy, even a pending petition, can impact any business, regardless of size.
APPA is proud to represent our members interest in this discussion by joining a coalition of major industry organizations, including the Pet Food Institute and the National Retail Federation, to file a letter with the Department of Commerce expressing significant concern over the scope of the Can Manufacturers Institute's (CMI) petition. The multi-association letter argues that the CMI's overly broad request to add filled cans as derivative articles to the existing Section 232 tariffs would cause irreparable economic harm, limit the on-shelf availability of critical products, and increase costs for consumers. This concerted action underscores the pet industry’s commitment to mitigating the massive cost increases a broad tariff would impose on canned pet food.
To view the multi-association comments for the section 232 inclusion request, click here.
For APPA members, should the government decide to move forward with the filled can initiative, the advice remains clear: proactive planning is essential.
If you have questions regarding trade or tariff issues and want to get your questions answered in real-time, please make sure you sign up for our upcoming Open Office Hours. As an APPA Member, if your question requires more research and background for an appropriate response, contact us, and we can set up a free question resolution consultation with Rebecca Rizzuti and her team.