Additional aluminum & steel derivatives now subject to duties
Date of publication: August 22, 2025
Late on August 15, 2025, U.S. Customs and Border Protection (CBP) published two Cargo Systems Messaging Service (CSMS) bulletins announcing an
additional 407 HTSUS subheadings
will be subject to 50% Section 232 duties on steel and aluminum derivatives
.- CSMS # 65936570 “GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products” and a list of new steel derivatives HTSUS can be found here.
- CSMS # 65936615 “GUIDANCE: Section 232 Additional Aluminum Derivative Tariff Inclusion Products” and a list of new aluminum derivatives HTSUS can be found here.
The related Federal Register Notice (FRN) 2025-15819 was not published until August 19, 2025, giving importers and their brokers virtually no time to prepare.
Background
On February 10, 2025, the President issued the Aluminum Proclamation 10895 adjusting imports of aluminum into the United States, (90 FR 9807) and the Steel Proclamation 10896 adjusting imports of steel into the United States (90 FR 9817).
Proclamations 10895 and 10896 required the Secretary of Commerce to establish a process for including additional derivative aluminum and steel articles within the scope of the ad valorem duties. The Secretary, through BIS, established the Section 232 Inclusions Process via an Interim Final Rule effective April 30, 2025, and the first two-week submission window opened on May 1, 2025 (90 FR 18780). BIS completed its first submission cycle of the Section 232 Inclusions and made the submissions available for public comment. After considering the comments received, the FRN of August 19th implements the Secretary's decisions and revises Annex I to add additional steel and/or aluminum derivative products.
The first inclusion requests from May have been added to the list of derivative products subject to Section 232 tariffs, apart from approximately 60 HTSUS numbers that are currently under separate investigations. It is anticipated that we will see a similar approach in future iterations of the inclusion request process. BIS will be accepting requests to extend the Section 232 tariffs to additional products during two-week windows opening three times a year at the beginning of each May, September, and January. It should be noted that the recent copper tariffs include a provision consistent with this process for the inclusion of additional derivative products, so this will be an ongoing effort for companies to monitor.
How are the tariffs applied?
The duties will apply to the new list of subheadings for “goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on August 18, 2025.” This change did not exclude goods already in transit. As noted in previous pronouncements, duty drawbacks will not be available.
Additionally, all HTSUS within scope must be admitted into a foreign-trade zone in privileged foreign status to fix the rate of duty that is assigned.
The 50% tariff imposed under Proclamations 10895 and 10896 will be assessed on these derivative products for the identified value of the steel or aluminum content in each product (or the entire content, when that lesser amount cannot be determined). The rest of the product (non-steel/non-aluminum parts) will be subject to reciprocal and other applicable tariffs.
Some exemptions exist for U.S.-processed products. If your product is processed in another country but made from steel/aluminum melted and poured in the US, it may be exempt from these tariffs.
UK products remain at 25% tariff unless the Secretary determines the UK has not complied with trade agreements after July 9, 2025. Additional rules and reporting requirements apply (see Annex I and II of the original FRN for details).
Additionally, the 200% duty on aluminum and aluminum derivatives originating from Russia remains in effect and should be applied to the full value of the imported goods where the country(ies) of smelt and cast are unknown.
What products are affected?
These codes cover a wide range of goods, including machinery, vehicles, tools, chemicals, and more — any product with steel or aluminum components. Many of these new HTS provisions would not normally be considered aluminum or steel derivative products. For example, the list includes items as diverse as dairy products (0402), food preparations (2106), petroleum oils (2710), and certain chemicals.
A list of affected HTSUS codes at the 4-digit level is shown below, and the complete list can be found in Annex 1 of the FRN.
The classifications added for steel derivative products outnumber those added for aluminum derivative products although, there are an increasing number of overlapping classifications that will require consideration of the impact of both tariffs. It is therefore possible that a specific product could be effectively exposed to a 100% tariff (50% for each) where steel and/or aluminum content cannot reliably be determined.
How to prepare
If you import products with steel or aluminum components, you may face new tariffs starting August 18, 2025.
- Review the list: Check if any of your imported products are listed under the new HTSUS codes in the Annex.
- Assess impact: Determine the steel or aluminum content in your products, as tariffs will be calculated based on this value.
- Update procedures: Make sure your customs declarations accurately reflect the steel/aluminum content and the correct HTSUS codes. Importers must accurately declare the amount (in kilograms) and value of steel or aluminum content in each product.
- Monitor exemptions: If you use US-origin steel or aluminum that is processed abroad, review exemption criteria carefully.
- Prepare for additional costs: Factor in the new tariffs when pricing products, negotiating contracts, and planning logistics.
- Stay informed: Watch for updates, as BIS may add or remove codes in the future and technical corrections may affect how tariffs are applied.
The official list of affected HTSUS codes is in the annexes of the notice, and available at regulations.gov. Additionally, BIS memoranda explaining the decisions are also posted there.
CBP has also posted FAQs specifically for steel and aluminum tariffs that will provide additional guidance. Importers should include this as a resource, along with their customs brokers, trade consultants, software providers and legal teams.
Conclusion
The ongoing BIS process for inclusion of additional commodities to the derivatives list for steel and aluminum tariffs (and copper in the future) poses an ongoing challenge for importers to ensure that their entries are filed in a compliant manner. Accurate reporting is critical, and penalties for errors are serious. Review your supply chain and customs procedures now to ensure compliance and manage costs. Underreporting or misdeclaration can result in severe penalties, including heavy fines, loss of import privileges, and possible criminal charges.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance, contact your Account Manager or Client Success Manager.