WHICH IMPORTS ARE SUBJECT TO THE NEW SECTION 232 WOOD PRODUCT TARIFFS?
Section 232 tariffs on timber, lumber, upholstered furniture, and wooden cabinets and vanities will take effect on October 14, 2025, following a White House proclamation issued under the Trade Expansion Act of 1962. The proclamation sets new duty rates and updates the Harmonized Tariff Schedule of the United States (HTSUS) to include subheadings 9903.76.01 through 9903.76.22.
HOW ARE DUTY RATES STRUCTURED FOR TIMBER, FURNITURE, AND CABINETRY?
According to the White House announcement and the HTSUS annex, the following rates will apply:
- 10 percent on softwood timber and lumber classified under heading 9903.76.01
- 25 percent on upholstered wooden furniture under heading 9903.76.02, increasing to 30 percent on January 1, 2026
- 25 percent on completed kitchen cabinets, vanities, and parts under heading 9903.76.03, increasing to 50 percent on January 1, 2026
Tariffs for goods originating in the United Kingdom, Japan, and the European Union are capped as follows:
- United Kingdom: 10 percent maximum rate (heading 9903.76.20)
- Japan: 15 percent maximum rate (heading 9903.76.21)
- European Union: 15 percent maximum rate (heading 9903.76.22)
HOW WILL THESE TARIFFS INTERACT WITH OTHER TRADE PROGRAMS AND AUTHORITIES?
Goods subject to these Section 232 tariffs will not be assessed additional duties under reciprocal or International Emergency Economic Powers Act (IEEPA) tariff programs. Specifically, they are excluded from the 40 percent IEEPA tariff on imports from Brazil and the 25 percent IEEPA tariff on imports from India tied to Russian oil.
Products that fall under both the new Section 232 wood provisions and the existing Section 232 measures on automobiles and auto parts will only be subject to the auto and parts tariffs. Similarly, goods that overlap with IEEPA tariffs on Canada or Mexico will only be subject to the new Section 232 wood tariffs.
The proclamation also removes more than 150 tariff subheadings in Chapter 44 from Annex II, which previously listed goods exempt from reciprocal tariffs. This revision takes effect on October 14, 2025.
WHAT ADMINISTRATIVE RULES AND ENTRY REQUIREMENTS WILL APPLY?
Drawback will be available for qualifying re-exports, but entries of affected products into a U.S. foreign-trade zone (FTZ) on or after October 14 must be admitted in privileged foreign status.
The White House directed the U.S. Department of Commerce to establish an inclusion process to add goods to the tariff list. It also authorized the Secretary of Commerce to impose specific, compound, or mixed tariff rates if an undervaluation risk is identified for any class of imports covered by this action.
As outlined in U.S. Note 37 to Subchapter III, Chapter 99 of the HTSUS, importers are required to furnish any information Customs and Border Protection (CBP) deems necessary to administer these tariff provisions. All antidumping, countervailing, and other duties will continue to apply in addition to the Section 232 tariffs.
HOW DO THE NEW HTSUS HEADINGS DEFINE THE SCOPE OF TARIFF COVERAGE?
The new HTSUS modifications establish seven distinct subheadings for wood products and country-specific rates:
- 9903.76.01 – Softwood timber and lumber (10 percent)
- 9903.76.02 – Upholstered wooden furniture (25 percent, rising to 30 percent)
- 9903.76.03 – Kitchen cabinets and vanities (25 percent, rising to 50 percent)
- 9903.76.20 – Wood products of the United Kingdom (10 percent cap)
- 9903.76.21 – Wood products of Japan (15 percent cap)
- 9903.76.22 – Wood products of the European Union (15 percent cap)
These headings are in addition to any special rates of duty otherwise applicable under trade agreements or preference programs.
WHAT STEPS SHOULD IMPORTERS TAKE BEFORE THE OCTOBER 14 IMPLEMENTATION?
Importers should begin an immediate review of their wood product classifications to determine potential exposure.
Recommended steps include:
- Verifying HTSUS classifications against headings 9903.76.01 through 9903.76.22
- Identifying FTZ admissions requiring privileged foreign status after October 14
- Coordinating with Customs brokers to ensure system updates for new Chapter 99 provisions
- Monitoring the Federal Register for guidance from the Department of Commerce and CBP regarding inclusion procedures, documentation, and valuation adjustments
- Partnering with trade compliance experts to model potential cost impacts and evaluate sourcing alternatives
Additional clarification from CBP and the Office of the U.S. Trade Representative (USTR) is expected prior to the effective date.
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