Section 232 Guidance on Additional Aluminum & Steel Derivative Tariff Inclusion Products
The following was taken in part from CSMS 65936570 & CSMS 65936615:
On February 10th, 2025, the President issued Proclamation 10895, “Adjusting Imports of Aluminum into the United States” (90 FR 9807) and Proclamation 10896, “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).
In Proclamation 10895 and 10896, the President authorized and directed the Secretary of Commerce to publish modifications to the HTSUS to reflect the amendments and effective dates in the proclamation.
Effective August 18th, 2025, in accordance with “Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process,” the Commerce Department will be adding additional steel and aluminum derivative products to Annex I of the HTSUS to be subject to Section 232 duties. Further, Annex II makes technical corrections to the Harmonized Tariff Schedule of the United States.
Application of Reciprocal Tariffs under EO 14257
The non-steel content of an article reported on a separate line is subject to Reciprocal Tariffs under HTS 9903.01.25.
The steel content subject to Section 232 duties is not subject to Reciprocal Tariffs under HTS 9903.01.33.
The non-aluminum content of an article reported on a separate line per the instructions above is subject to Reciprocal Tariffs under HTS 9903.01.25.
The aluminum content subject to Section 232 duties per the instruction above is not subject to Reciprocal Tariffs under HTS 9903.01.33.
Drawback
No drawback shall be available with respect to the duties imposed pursuant to Proclamation 10896.
Consult the Section 232 Tariffs on Steel and Aluminum Frequently Asked Questions (FAQs) for additional guidance, including on reporting country of melt and pour, smelt and case, plus determining the value of steel / aluminum content and reporting requirements on goods subject to both steel and aluminum duties.
For reference, a summary of Section 232 Chapter 99 HTSUS steel classifications is can be found here and the aluminum classifications here. 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.
