The below was published on CSMS messages 64348288 and 64348288 on 3/7/2025. On February 10, 2025, the President issued Proclamation 10895 on Adjusting Imports of Aluminum into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), imposing ad valorem tariffs on all imports of aluminum articles and derivative aluminum articles from all countries, effective March 12, 2025.  See 90 FR 9807 and 90 FR 11251. In addition, the President issued Proclamation 10896 on Adjusting Imports of Steel into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), imposing 25 percent ad valorem tariffs on all imports of steel articles and derivative steel articles from all countries, effective March 12, 2025.  See 90 FR 9817 and 90 FR 11249.

GUIDANCE: Aluminum

Effective with respect to aluminum articles and derivative aluminum articles entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on March 12, 2025, the following Harmonized Tariff Schedule of the United States (HTSUS) classifications and 25 percent duty rate apply:

• 9903.85.02: Aluminum products except derivative articles listed in subdivision (g).
• 9903.85.04: Derivative aluminum products listed in subdivision (i) (existing aluminum derivative articles subject to Section 232).
• 9903.85.07: Derivative aluminum products listed in subdivision (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232).

Effective with respect to aluminum articles and derivative aluminum articles entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on March 12, 2025, the following HTS classification and 0 percent duty rate applies:

• 9903.85.09: Derivative steel articles listed in subdivision (j) or (k) (new derivative aluminum articles), where the derivative aluminum products were processed in another country from aluminum articles that were smelted and cast in the United States.

Effective with respect to aluminum articles and derivative aluminum articles entered for consumption, or withdrawn from warehouse for consumption, on or after a date to be certified in the Federal Register by the Secretary of Commerce, the following HTS classification and 25 percent duty rate applies:

• 9903.85.08:  Derivative aluminum products listed in subdivision (k) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232):  the import duty is based upon the value of the aluminum content (see instructions below).

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.

Example Commercial Invoice:

Duties for Aluminum from Russia

The 200 percent duties on any aluminum products and derivative aluminum products subject to Section 232 that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, are still in effect.  These duties are to be applied on the entire value of the imported good.  Importers should continue to report HTS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products; subject to the 200 percent Russia aluminum duties.

Smelt and Cast Reporting Requirements

To report the primary country of smelt, secondary country of smelt, or country of most recent cast importers must report the International Organization for Standardization (ISO) code on aluminum articles and derivative aluminum articles on all countries subject to section 232.  

Exclusions and Drawback

Importer-specific product exclusions for Section 232 duties that active in ACE shall remain effective until their expiration date or until excluded product volume is imported, whichever occurs first.  All general approved exclusions (GAEs) shall expire on March 11, 2025, and products will be subject to 25 percent ad valorem duties on March 12, 2025.

No drawback shall be available with respect to the duties imposed.

Quota

All Section 232 tariff rate and absolute quotas shall expire on March 11, 2025.  All Section 232 tariff rate and absolute quotas entries must be presented to CBP during official office hours per 19 CFR 132.3, 8:30 a.m. to 4:30 p.m. local port time, on March 11, 2025. Entries that do not achieve quota status by 4:30 local port time on March 11, 2025, do not qualify for the Section 232 quotas and must be refiled as non-quota entries on March 12, 2025.

Foreign Trade Zone (FTZ) Any aluminum articles or derivative aluminum articles, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation and that is admitted into a U.S. foreign trade zone on or after the Commerce certification date, in accordance with clause 9, may be admitted only under “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading.

GUIDANCE: Steel

Effective with respect to steel articles and derivative steel articles entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on March 12, 2025, the following Harmonized Tariff Schedule of the United States (HTSUS) classifications and 25 percent duty rate apply:

9903.81.87: Iron or steel products listed in subdivision j (except derivative articles)

9903.81.88: Iron or steel products except for derivative articles listed in subdivision (l), (m) and (n) that are admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025.

9903.81.89: Derivative iron or steel products listed in subdivision (l) (existing steel derivative articles subject to Section 232).

9903.81.90: Derivative iron or steel products listed in subdivision (m) (new steel derivative articles classified in Chapter 73 subject to Section 232).

9903.81.93: Derivative products of iron or steel, as specified in subdivisions (l) and (m) (existing derivative steel products, and new derivative steel products in Chapter 73) admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 1, 2025.

Effective with respect to steel articles and derivative steel articles entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on March 12, 2025, the following HTSUS classification and 0 percent duty rate applies:

• 9903.81.92: Derivative steel or iron products listed in subdivision (m) or (n) (new derivative steel articles) where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States.
  • HTS 9903.81.92 also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before March 12, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after March 12 (see Foreign Trade Zone section below).

Effective with respect to steel articles and derivative steel articles entered for consumption, or withdrawn from warehouse for consumption, on or after a date to be certified in the Federal Register by the Secretary of Commerce, the following HTS classification and 25 percent duty rate applies to the value of the steel content:

• 9903.81.91: Derivative iron or steel products listed in subdivision (n) (new steel derivative articles not classified in Chapter 73 subject to Section 232):  the import duty is on the value of the steel content (see instructions below).
  • 9903.81.91 also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before March 12, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after a date to be certified in the Federal Register by the Secretary of Commerce (see Foreign Trade Zone section below).

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 Example Commercial Invoice:

The reporting of the country of melt and pour and applicability code is mandatory for both steel and steel derivatives.  To report the country of melt and pour, importers must report the International Organization for Standardization (ISO) code on steel articles and derivative steel articles subject to Section 232.  For steel articles, importer must report the ISO code where the steel was originally melted and poured.  For steel derivatives, importers must report the ISO code where the steel was originally melted or “OTH” (for other countries).  For products melted and poured in the United States, importers must indicate “US” as the country of melt and pour.

Exclusions and Drawback

Importer-specific product exclusions for Section 232 duties that are active in the Automated Commercial Environment (ACE) shall remain effective until their expiration date or until excluded product volume is imported, whichever occurs first.  All general approved exclusions (GAEs) shall expire on March 11, 2025, and products will be subject to 25 percent ad valorem duties on March 12, 2025.

No drawback shall be available with respect to the duties imposed.

Quotas

All Section 232 tariff rate and absolute quotas shall expire on March 11, 2025.  All Section 232 tariff rate and absolute quotas entries must be presented to CBP during official office hours per 19 CFR 132.3, 8:30 a.m. to 4:30 p.m. local port time, on March 11, 2025.  Entries that do not achieve quota status by 4:30 p.m. local port time on March 11, 2025, do not qualify for the Section 232 quotas and must be refiled as non-quota entries on March 12, 2025.

Foreign Trade Zone (FTZ)

Any steel article or derivative steel article, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation and that is admitted into a U.S. FTZ on or after 12:01 a.m. eastern daylight time on March 12, 2025, must be admitted and granted as “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading. 

Any steel article or derivative steel article, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation, and that was admitted into a U.S. FTZ and granted “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 12, 2025, will likewise be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading added by this proclamation.

For steel and steel derivative articles admitted into a U.S. foreign trade zone and granted “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 12, 2025, and entered on or after 12:01 a.m. eastern daylight time on March 12, 2025, use the HTS classification below corresponding to the type of imported good:

• 9903.81.88: Iron or steel products (including those classified under GAEs).
• 9903.81.93: All iron or steel derivative products, except as noted below: 
  • 9903.81.91: Iron or steel derivative products classified outside of Chapter 73.
  • 9903.81.92: Iron or steel derivative products with a melt and pour of United States.

For information on the new HTS numbers required, please reference the 232 HTS chart.

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.