In CSMS# 65236645 & CSMS #65236374, the updated guidance in regards to Import Duties on Imports of Steel / Aluminum and Steel / Alum Derivative Products was provided:

Background: On June 3rd, 2025, the President issued a Proclamation, Adjusting Imports of Aluminum and Steel into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862) (“Section 232”), increasing from 25 percent ad valorem to 50 percent ad valorem the tariffs previously imposed pursuant to Section 232 on certain imports of aluminum articles and derivative aluminum articles from all countries, effective for covered goods entered for consumption, or withdrawn from warehouse for consumption, on and after 12:01AM EDT on June 4th, 2025, except for products of the United Kingdom for which the Section 232 tariffs on such imports will remain at 25 percent ad valorem.

In a significant change, the June 3rd Proclamation now permits importers to pay the 232 duties on only the steel and aluminum content, regardless of the Chapter under which the product is classified:

As of June 4th, 2025, for all aluminum and derivative aluminum articles classified in Chapter 76 that are subject to Section 232 duties under any Chapter 99 HTSUS heading, the applicable Section 232 duty is assessed on the value of the aluminum content.

As of June 4th, 2025, for all steel and steel derivative articles classified in Chapter 73 that are subject to Section 232 steel duties under any Chapter 99 HTSUS heading, the applicable Section 232 duty is assessed only on the value of the steel content.

Per the Section 232 FAQs:

How to determine the value of aluminum or steel content for derivative products outside of CH. 76 or 73?

The value of the steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a. Thus, the value of the steel/aluminum content is the total price paid or payable for that content, which is the total payment (direct or indirect, and exclusive of any costs, charges, or expenses incurred for transportation, insurance, and related services incident to the international shipment of the merchandise from the country of exportation to the country of importation) made/to be made for the steel/aluminum content by the buyer to, or for the benefit of, the seller of the steel/aluminum content. Normally, this would be based on the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content.

US Customs and Border Protection (CBP) has intensified its review of the calculation method for the steel/aluminum and non-steel/aluminum content. We are aware that the revisions in the June 3^rd Proclamation may have created confusion. It has been suggested that the non-steel/non-aluminum additive products used in the production of derivative products (e.g., alloying additives or powder coating) or costs of converting aluminum/steel raw material into the derivative product (e.g., labor costs, utilities, fixed costs, overhead, and profit) can be itemized to avoid assessment of the 232 duties on the non-steel/non-aluminum additives and conversion costs. This cannot be confirmed as, unfortunately, there has been no further guidance outside of the FAQs. We encourage our importers to be prepared and have the proper documentation available to support the valuation of their steel/aluminum entries.

One additional note, effective June 4th, 2025, the non-steel/non-aluminum content of the entered merchandise is subject to applicable reciprocal tariff rate based on country of origin.

RIM strongly encourages our clients to seek the advice of a Trade Attorney to ensure that the proper method of appraisement is correctly applied to determine the value of your goods.

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