US announces new 25% tariffs on steel imports

How this will change existing steel tariffs

Effective 12:01 Eastern on March 12, 2025, existing exclusions and any country specific agreements will no longer apply. The 25% ad valorem tariffs will apply to all steel and derivative steel products.
Country exemptions will no longer exist – the tariff will apply regardless of country of origin.
The exclusion process with Bureau of Industry and Security (BIS) will not exist going forward. Any existing exclusions will be allowed to continue until their expiration date or the product volume associated with that exclusion is filled, whichever occurs sooner. Additionally, any existing General Approved Exclusions will be terminated.
It is anticipated that the steel derivative list will noticeably expand is identified in the published Annex I. For these products, only that portion of the item consisting of steel will be subject to the tariff. This broadening will not apply where the steel has been melted and poured in the US.
Commerce is requiring the importer to declare both the value and the quantity (in kgs) of the steel components contained in certain derivative products classified outside of HTSUS Chapter 73.
Importers will be required to provide CBP with whatever information necessary to identify the steel content "used" in the manufacture of steel derivative products within scope, with CBP obligated to "implement the information requirements as soon as practicable."
Guidance as to how any amount of steel contained within listed derivative products is to be calculated and/or supported has not been provided.
No Drawback will be allowed.
For Foreign Trade Zones (FTZ), any entry of steel or steel derivative products into a FTZ must be in privileged foreign status (except for products eligible to enter the FTZ in domestic status) to ensure applicability of the tariff at the time of zone withdrawal for consumption. Importantly, products admitted in PF status prior to that date will also be subject to the tariff upon subsequent zone withdrawal.
The White House has directed the Secretary of Commerce to develop, within 90 days after publication of the proclamation in the Federal Register, a mechanism that will allow producers to request Commerce to expand the list of steel derivative products (i.e., subject to the additional 25% duties/tariffs).

Current steel tariffs (2018-2024 proclamation)

Those items are identified as follows and will require the importer to declare
HTSUS subheading 9903.81.87
at time of entry:

flat-rolled products provided for in headings 7208, 7209, 7210, 7211, 7212, 7225 or 7226.
bars and rods provided for in headings 7213, 7214, 7215, 7227, or 7228; angles, shapes and sections of 7216 (except subheadings 7216.61.00, 7216.69.00 or 7216.91.00); wire provided for in headings 7217 or 7229; sheet piling provided for in subheading 7301.10.00; rails provided for in subheading 7302.10; fish-plates and sole plates provided for in subheading 7302.40.00; and other products of iron or steel provided for in subheading 7302.90.00.
tubes, pipes and hollow profiles provided for in heading 7304 or 7306; tubes and pipes provided for in heading 7305.
ingots, other primary forms and semi-finished products provided for in heading 7206, 7207 or 7224.

For following steel derivative products from the original Section 232 investigation, importers must declare
HTSUS subheading 9903.81.89
:

nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in powder-actuated handtools, threaded (described in subheading 7317.00.30).
nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505, 7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65).
bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30).
body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).

For newly designated steel derivative products classified in Chapter 73 of the HTSUS (i.e., the 150+ different tariff codes listed in the newly created Note 16(m) to Subchapter III of Chapter 99 of the HTSUS), importers must declare
HTSUS subheading 9903.81.90
. These HTSUS numbers can be found on pages 5-6 of the Federal Register Notice.
For the steel derivative products that are classified outside of Chapter 73 of the HTSUS (i.e., in one of the new 12 HTSUS subheadings outside of Chapter 73 identified as steel derivatives), importers must declare
HTSUS subheading 9903.81.91.
However, the 25% duty on these products will not be in effect until the Commerce Department publishes further guidance.
Certain steel and derivative steel products involved in FTZ transactions are to be reported under
HTSUS subheading 9903.81.88
(for the 5 types of steel products listed in (i) thru (v) above) or
9903.81.93
(for the 4 types of steel derivative products listed above in (A) thru (D) and the 150+ different tariff codes listed in the newly created Note 16(m) to Subchapter III of Chapter 99 of the HTSUS).
Although certain steel derivative articles that are processed in another country using steel articles melted and poured in the United States are exempt from the 25% tariffs, the Commerce Department will be tracking such imports by requiring importers to nevertheless also declare them under
HTSUS subheading 9903.81.92
.

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