New 25% tariffs on steel and aluminum imports
Date of update: April 3rd, 2025
Background
On March 12th, 2025, new tariffs on US imports of Steel and Aluminum went into effect. Within the following Help Center articles your ONESOURCE team covers the background regulations as well as high level details on these new tariffs.
- US Announces New 25% Tariffs on Steel Imports (Date of publication: February 13th, 2025) (Date of the last update: March 5th, 2025)
- US Announces New 25% Tariffs on Aluminum Imports (Date of publication: February 13th, 2025)(Date of the last update: March 5th, 2025)
Overall guidance
Given the complexity around the requirements within these regulations your ONESOURCE team has added some additional information below on the practical implementation of these new requirements and what you can do to ensure compliance with them:
- US Customs and Border Protection published the following CSMS messages with details concerning the implementation of these new tariffs:
- CBP has also developed an FAQ page in support of 232 and they indicated they would be updating regularly as they have more information for trade:
Some key points extracted from these FAQs are:
How to report the country of melt and pour when the product is subject to Section 232 derivative measures, but the importer does not know the country of melt and pour?
For derivative steel, filers can report OTH for the country of melt and pour.
How to report the country of smelt and cast when the product is subject to Section 232 derivative measures, but the importer does not know the country of smelt and cast?
For derivative aluminum, the filer, as an interim solution, may report any country other than the United States if the filer does not know the country of smelt or cast. Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual countries of smelt or cast. For a long-term solution, CBP is looking into other options for reporting an unknown country of smelt or cast. CBP will provide guidance through CSMS when more information is available.
What is the proper method to submit entries for products that do not contain steel or aluminum content, and are not subject to Section 232 measures, but still require the steel melt and pour and aluminum smelt and cast information to be reported?
Where the product does not contain steel or aluminum content, but has a HTS classification that would be subject to Section 232 measures on derivative steel or aluminum articles if it contained steel or aluminum, ACE will still require the steel melt and pour or aluminum smelt and cast country to be reported.
For such situations for steel derivative HTS classifications, where the steel country of melt and pour is required, report the country reported as the country of origin of the non-steel article as the steel country of melt and pour.
For such situations for aluminum derivative HTS classifications, where the aluminum country of smelt and cast is required, report "IV" for the secondary country of smelt, and report the country reported as the country of origin of the non-aluminum article as the secondary country of smelt code, and as the country of cast.
For all other fields, continue to follow the CATAIR including reporting on one entry summary line for non-Section 232 entries.
If a good has a HTS classification subject to Section 232 measures on derivative steel and aluminum measures, and contains steel or aluminum content, see CSMS # 64384423 and # 64384496 for reporting instructions.
Steel and Aluminum Declaration Reporting
More HTS numbers have been flagged for required Steel and Aluminum Declaration reporting. You may not have needed these menu options in the past and your ONESOURCE team is working to get them added as quickly as possible. Below are some links if you are a first-time user of the Steel and Aluminum Declaration reporting:
If your part numbers in Global Classification have a static Aluminum Smelt/Cast and Steel Melt/Pour country, it is possible to enable the following fields to feed this information over to transactions.
Steel and Aluminum Chapter 99 Reporting
- There are several new chapter 99 tariffs that are being introduced within these regulations.
- The chapter 99 tariffs for aluminum and steel imports need to be utilized when filing entries for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 12, 2025.
- You should monitor official guidance from CBP for the most up-to-date information.
Full value steel/aluminum content reporting ONESOURCE guidance (effective March 12th, 2025)
For Primary and derivative steel and aluminum products that will be reported at full value, the Item Master Custom Rule tool within the application can assist in applying the required chapter 99 tariffs. These rules will look similar to other rules you may have in place for reporting of Section 301 or IEEPA tariffs, etc. Refer to the Help Center for information on how to use
Item Master Custom Rules
tool. Note that within Help and Support there are a number of videos showing how to add in custom rules.- For full value reporting, the entire part's value will have 25% applied and appear on a single line upon entry.
- The rule ensures all relevant 99s are arranged according to CBP requirements, followed by the base HTS. The value for all 99s, including the 232 99, will be 0 and fully allocated to the base.
Partial value steel/aluminum content derivative reporting ONESOURCE guidance (effective March 12th, 2025)
Within the CSMS messages referenced earlier, US Customs and Border Protection provided some guidance on how derivates are to be reported:
Reporting instructions for duties based on steel content
For new steel derivatives outside of Chapter 73, the 25 percent duty is to be reported with HTS 9903.81.91 based upon the value of the steel content.
If the value of the steel content is the same as the entered value or is unknown, the duty must be reported under HTS 9903.81.91 based on the entire entered value, and report on only one entry summary line.
In the case where the value of the steel content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-steel content while the second line will represent the steel content. Each line should be reported in accordance with the following instructions.
Non-Steel content, first line:
- Ch 1-97 HTS, this same HTS must be reported on both lines.
- Country of origin, same must be reported on both lines.
- Total entered value of the article less the value of steel content.
- Report the total quantity of the imported goods.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Steel content, second line:
- Same Ch. 1-97 HTS reported on the first line.
- Same country of origin reported on the first line.
- Report 0 for quantity for the Ch. 1- 97 HTS.
- Report the value of steel content.
- Report the Section 232 duties based on the value of steel content with HTS 9903.81.91.
- Report a second quantity (of the steel content) in kilograms with the HTS 9903.81.91.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Reporting instructions for duties based on aluminum content (HTS 9903.85.08)
For new aluminum derivatives not classified in Chapter 76, the 25 percent duty is to be reported based upon the value of the aluminum content.
If the value of the aluminum content is the same as the entered value or is unknown, duty must be reported under 9903.85.08 based on the entire entered value, and on only one entry summary line.
In the case where the value of the aluminum content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-aluminum content, the second line will represent the aluminum content. Each line should be reported in accordance with the following instructions.
Non-Aluminum content, first line:
- Ch. 1-97 HTS, this same HTS must be reported on both lines.
- Country of origin, same must be reported on both lines.
- Total entered value of the article less the value of aluminum content.
- Report the total quantity of the imported goods.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Aluminum content, second line:
- Same Ch. 1-97 HTS reported on the first line.
- Same country of origin reported on the first line.
- Report 0 for quantity for the Ch. 1-97 HTS.
- Report the value of the aluminum content.
- Report the Section 232 duties based on the value of aluminum content with HTS 9903.85.08.
- Report a second quantity (of the aluminum content) in kilograms with the HTS 9903.85.08.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Within the ONESOURCE application, to support the derivative reporting requirements as a breakout of the aluminum or steel partial content defined above, we have been developing additional reporting abilities within IMCR to make this process easier. There are many open questions with CBP on exactly how they want to handle the various scenarios that customers require. As we are getting the answers, we are working on solutions. We apologize for the delay as we gather more information from US Customs on the requirements for this subset of products within these new regulations. We will keep you updated. We are committed to helping guide our customers through these fast-paced regulatory changes as efficiently as possible.
Here are some details on how rules would be setup for derivative reporting using Item Master Custom Rules:
1. Partial value reporting (applying 0 value to the 232 line for non metal parts)
- CBP has indicated that if a part is on the derivative list and contains no metal, importers can elect to not include the 232 chapter 99.
- Note that even if the 99 is omitted, there is still a requirement to complete the additional declaration information (Steel Melt & Pour and Aluminum Smelt & Cast). Please be sure to follow the guidance listed above pulled from the 232 FAQ page on how to submit this information for non-metal parts.
2. Partial Value reporting: – Note that this is pending development work and is not yet available
- For partial value reporting the value of the part can be split out so that only the metal content value is assessed the 25% duty
- For these rules, the 232 chapter 99 will come after the base, indicating to the system that two lines will be created (one for the base and relevant 99s without the 232 chapter 99, and a second with the base and relevant 99s with the 232 chapter 99)
- The value on the base record would be the non-metal content value, and the HTSUOMConvFactor is based on the physical part (not splitting out quantities between metal and non-metal portions)
- The value on the 232 chapter 99 is the metal content value, and the HTSUOMConvFactor is the quantity in KG of the part
Entry rejection message – Quick guide
Here is a quick guide on what steps to take when seeing rejections on entries with 232 goods:
Rejection message | Rejection code | Rejection explanation | Notes |
|---|---|---|---|
TRFF ADJSTMNT HTS OR EXCLSN MISSING | 771 | The article, found to be subject to a remedy or other measure (e.g., a Section 232 or Section 301 measure), is missing either the required remedy HTS (50-Record) or an indication of an 'exclusion' (e.g., a 54-Record Product Exclusion Identifier). | Check the link for missing chapter 99 for Section 232 reporting |
ADDTNL DEC TYPE RQRD FOR ARTICLE | 794 | An Importer's Additional Declaration Detail is required for the article. | Check the Alum Smelt and Cast or the Steel Melt and Pour (depending on tariff) for missing declarations |
ADDTNL DEC TYPE NOT ALLWD FOR ARTICLE | 733 | The Importer’s Additional Declaration Type Code (54-Record) specified is not allowed to be used with one or more of the HTS numbers (50-Record) specified for the ES line. | Review and see if a steel additional declaration was added to a non-steel part, or vice versa with aluminium |
FORMAL MPF REQUIRED-ARTICLE NOT EXEMPT | 633 | If a formal class code '499' fee has not been submitted for the line of a formal summary but the article is not MPF exempt, this error will result. | Submit a ticket with the support team to review |