New Guidance on Section 232 for Steel/Iron and Aluminum Derivative Products

New Guidance on Section 232 for Steel/Iron and Aluminum Derivative Products

CBP issued two new CSMS 65936570 & 65936615 messages late Friday night with guidance on adding additional steel derivative products and aluminum derivative products to Annex I. 

With no exception for goods already in transit and virtually no advance notice, the Trump Administration on Friday announced 407 new tariff provisions that will be subject to 50% Section 232 aluminum and steel tariffs beginning at midnight on August 18, 2025.

The new list sweeps in a wide range of HS codes that historically have never been considered “steel” or “aluminum derivative” products. Many of these provisions fall well outside any reasonable interpretation of downstream aluminum or steel goods.

For example, the tariffs will now extend to items as diverse as:

• Dairy products (0402)
• Food preparations (2106)
• Petroleum oils (2710)
• Various chemicals

While the 50% tariff is said to apply only to the aluminum/steel components of these goods (e.g., packaging, containers, or related materials), the scope of coverage highlights just how far this administration is casting its tariff net.

We have included the list for both steel and aluminum that have been added that will now be subject to 50% ad valorem duty on the value of the steel and aluminum content for all countries except the United Kingdom, they are at 25% ad valorem duty on the value of the steel or aluminum content.  

If the derivative steel/iron derivative was processed in another country from steel articles that were melted and poured in the United States, the ad valorem rate will be 0%.  Same applies for aluminum products that are processed in another country from the aluminum articles smelted and cast in the United States subject to Section 232, the ad valorem rate will be 0%.

Application of Reciprocal Tariffs under EO 14257

• 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. 

Smelt and Cast Reporting Requirements for Aluminum

Primary country of smelt and/or secondary country of smelt must be reported and if either the derivative aluminum primary and/or secondary country of smelt or country of cast is unknown, when reporting “unknown”, the 200 percent Section 232 duties for Russia aluminum will be assessed on the entry summary line.

Review the full list for Aluminum Derivatives here: New Guidance on Aluminum Derivatives_8.18.25.docx

Application of Reciprocal Tariffs under EO 14257

• The non-steel content of an article reported on a separate line per the instructions identified in CSMS 65236374, 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.

Review the full list for Steel Derivatives here: New Guidance on Steel Iron Derivatives_8.18.25.docx

If you have any further questions regarding steel/iron or aluminum derivatives, please contact your Western Overseas representative and they will be able to assist you.