According to a pair of press releases today, Monday, March 3rd, by the Commerce Department, tariffs on some of the new aluminum and steel derivatives listed in an annex to President Donald Trump’s proclamation expanding the Section 232 tariffs will take effect on March 12th, 2025.

While the effective date remains uncertain for tariffs on the new steel and aluminum derivatives outside of Chapters 73 and 76 of the tariff schedule (110 subheadings and 12 subheadings, respectively), the notices say that the 19 new subheadings for derivatives in Chapter 76 and the 157 new subheadings in Chapter 73 will face tariffs on March 12th under new subheadings 9903.85.07 and 9903.81.90.

The original proclamations released on February 10th had specified that the new aluminum derivatives within Chapter 76 would be subject to tariffs on March 12th, but didn’t say the same for steel.

Tariffs on the new derivatives outside of Chapters 73 and 76 will take effect “upon public notification of the Secretary of Commerce.” Those tariffs will apply only to the derivatives’ aluminum or steel content, respectively, and the Commerce Department apparently has yet to determine that systems are in place to process and collect tariff revenue for such articles, as required by the original proclamation.

The Commerce Department notice that was released on March 3rd also lays out tariff treatment for all goods subject to the newly expanded Section 232 tariffs, including goods newly subject to the tariffs due to the elimination of quota and duty exemption deals with Canada, Mexico, the EU, and other countries.

• Note that importers are required to report to US Customs and Border Protection (CBP) the primary country of smelt, secondary country of smelt, and country of cast on imports of all aluminum articles subject to the aluminum and aluminum derivatives Section 232 measures.
• All anti-dumping, countervailing, or other duties and charges applicable to such goods shall continue to be imposed for both aluminum and steel.
• Derivative aluminum products for which entry is claimed under a provision of chapter 98 and which are subject to the additional duties prescribed herein shall be eligible for and subject to the terms of such provisions and applicable CBP regulations, except that duties under subheading 9802.00.60 shall be assessed based upon the full value of the imported article. No claim for entry or for any duty exemption or reduction shall be allowed for such derivative aluminum products under a provision of chapter 99 that may set forth a lower rate of duty or provide duty-free treatment, taking into account information supplied by CBP, but any additional duty prescribed in any provision of this subchapter or subchapter IV of chapter 99 shall be imposed in addition to the duty in headings 9903.85.04, 9903.85.07 or 9903.85.08.
• For any such derivative iron or steel products, goods for which entry is claimed under a provision of chapter 98 and which are subject to the additional duties prescribed herein shall be eligible for and subject to the terms of such provision and applicable CBP regulations, except that duties under subheading 9802.00.60 shall be assessed based upon the full value of the imported article.

RIM will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative should you have any further questions.