Section 232 Additional Steel / Aluminum Derivative Tariff Inclusion Products

Noel Tran
4 hours ago
3 min read

On February 10, 2025, the President issued Proclamation 10896, expanding Section 232 tariffs to cover additional steel derivative products. On August 15, 2025, U.S. Customs and Border Protection (CBP) released guidance and further detailing the products and applicable duties. These changes will impact importers through higher tariffs on affected steel/ aluminum derivatives. Below is a summary of what U.S. importers need to know to ensure compliance.

CBP Guidance:

Effective Date:

Duties apply beginning August 18, 2025 at 12:01 a.m. EDT, including goods entered for consumption or withdrawn from warehouse for consumption on or after this date. Goods already shipped but arriving after this time will not be exempt.

Applicability:

The Section 232 tariff is in addition to any other applicable duties, taxes, fees, or trade remedies (e.g., antidumping/countervailing duties, Section 301 tariffs, or retaliatory tariffs).

Filing requirements:

Importers must report the correct Chapter 99 subheading in addition to the regular HTS classification on CBP entry summaries. Failure to include the appropriate Chapter 99 provision will result in rejection of the entry and may delay cargo release.

HTSUS Lists:

Updated List of Steel HTSUS Subject to Section 232 Duties can be accessed here.
Update List of of Aluminum HTS Subject to Section 232 Duties can be accessed here.

Rates by Country:

Product Type	Country of Origin / Processing	HTS Heading	Duty
Steel Derivative	All except UK	9903.81.90 / 91	50% ad valorem
Steel Derivative	UK only	9903.81.97 / 98	25% ad valorem
Steel Derivative	US-melted, processed abroad	9903.81.92	0% ad valorem
Aluminum Derivative	All except UK	9903.85.07 / 08	50% ad valorem
Aluminum Derivative	UK only	9903.85.14 / 15	25% ad valorem
Aluminum Derivative	US-smelted, processed abroad	9903.85.09	0% ad valorem
Aluminum Derivative	Russia	9903.85.68 / 70	200% ad valorem

Quota and exclusion treatment:

Current product exclusions and quota-based exemptions under Section 232 remain applicable, but only if an exclusion is approved for the specific derivative product HTSUS classification.

Other Information:

Reciprocal Tariffs: Non-steel/aluminum content of affected goods may be subject to reciprocal tariffs (HTS 9903.01.25). Steel/aluminum content subject to Section 232 duties is not affected by reciprocal tariffs under HTS 9903.01.33
Drawback: No drawback (refund of duties) is available.
Foreign Trade Zone (FTZ) Guidance
- For steel, products admitted to FTZs before August 18, 2025, and granted “privileged foreign status” still face duties upon consumption regardless of zone status
- For aluminum, FTZ admissions are limited to “privileged foreign status” only, and applicable duties apply upon consumption; smelt/cast reporting requirements still apply
Smelt and Cast Reporting (Aluminum Only)

Practical Tips for Importers:

✅ Review Your Product Classifications Immediately

✅ Apply the correct duty rate based on country of origin

✅ Maintain Clear Documentation

✅ Don’t Rely on Drawback

✅ Separate Metal and Non-Metal Content

✅ Partner with a licensed Customs Broker Early

Contact Spirit CHB Inc – A Trusted U.S. Customs Brokerage with 20+ Years of Experience

📧 Import@spiritchbinc.com📞 714-383-9973

📌 Disclaimer & Contact Information

This blog post is intended to provide general information. It does not constitute legal advice or a comprehensive compliance guide. For specific questions or assistance with your import transactions, please consult official U.S. Customs and Border Protection resources or reach out to a licensed customs broker.

For more information, visit the official CBP website: https://www.cbp.gov

Or contact Spirit CHB, Inc. – A Trusted Customs Brokerage📞 Phone: (714) 383-9973