U.S. Customs and Border Protection (CBP) issued guidance detailing how importers must file entries for the newly added steel and aluminum derivative products subject to Section 232 duties. This follows the Bureau of Industry and Security’s expansion of covered Harmonized Tariff Schedule of the United States (HTSUS) codes effective August 18, 2025. CBP’s instructions confirm duty rates, entry filing rules, smelt and cast reporting requirements, and the treatment of non-metallic content.
READ ABOUT THE EXPANDED SECTION 232 STEEL AND ALUMINUM PRODUCTS HERE: https://www.greenworldwide.com/section-232-steel-and-aluminum-derivative-products-expansion-effective-august-18-2025/
WHAT DUTY RATES APPLY TO STEEL DERIVATIVE PRODUCTS?
Importers must classify derivative steel products under specific Chapter 99 HTSUS provisions, with duties assessed only on the steel content.
This includes:
- 50% ad valorem under HTS 9903.81.90 / 9903.81.91 for all countries except the United Kingdom.
- 25% ad valorem under HTS 9903.81.97 / 9903.81.98 for the United Kingdom.
- 0% ad valorem under HTS 9903.81.92 when processed abroad from U.S.-melted and poured steel.
For newly added steel derivative products admitted to a U.S. FTZ with privileged foreign status before August 18, 2025, CBP confirmed that those goods remain subject to the applicable Section 232 Chapter 99 provisions when entered for consumption on or after August 18.
DOWNLOAD THE FULL HTSUS STEEL & DERIVATIVE PRODUCTS LIST HERE: https://content.govdelivery.com/attachments/USDHSCBP/2025/08/15/file_attachments/3358116/Updated%20steelHTSlist%20081525.docx
WHAT DUTY RATES APPLY TO ALUMINUM DERIVATIVE PRODUCTS?
For aluminum derivative products, CBP specified the following Chapter 99 provisions:
- 50% ad valorem under HTS 9903.85.07 / 9903.85.08 for all countries except the United Kingdom.
- 25% ad valorem under HTS 9903.85.14 / 9903.85.15 for the United Kingdom.
- 0% ad valorem under HTS 9903.85.09 for articles processed abroad from U.S.-smelted and cast aluminum.
For Russian-origin products, or where any amount of primary aluminum is smelted or cast in Russia, a 200% ad valorem duty remains in effect. These duties apply to the full value of the imported article and must be reported under HTS 9903.85.67 / 9903.85.68
DOWNLOAD THE FULL HTSUS ALUMINUM & DERIVATIVE PRODUCTS LIST HERE: https://content.govdelivery.com/attachments/USDHSCBP/2025/08/15/file_attachments/3358120/Updated%20aluminumHTSlist%20081525.docx
WHAT ARE THE NEW SMELT AND CAST REPORTING REQUIREMENTS?
CBP now requires importers of aluminum derivative products to report ISO country codes for:
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Primary country of smelt,
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Secondary country of smelt, and
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Most recent country of cast.
If “UN” (unknown) is reported for any field, the 200% Russia duty will automatically be applied. Importers declaring recycled-only aluminum must provide manufacturing records to substantiate the claim. These reporting requirements also apply to FTZ withdrawals for consumption.
HOW ARE NON-STEEL AND NON-ALUMINUM CONTENTS TREATED?
CBP emphasized that reciprocal tariffs under HTS 9903.01.25 continue to apply to the non-steel and non-aluminum content of covered goods. Section 232 duties remain limited to the metallic content. This ensures segmented duty treatment and prevents overlap between reciprocal tariffs and Section 232 duties.
ARE THERE FTZ AND DRAWBACK LIMITATIONS?
No drawback is available for duties imposed under Proclamations 10895 and 10896. For aluminum articles and aluminum derivative articles admitted on or after August 18, 2025, admission is only under privileged foreign status, and smelt and cast reporting also applies to FTZ withdrawals for consumption.
WHAT ACTIONS SHOULD IMPORTERS TAKE TO REMAIN COMPLIANT?
Importers should take immediate steps to align with CBP’s requirements:
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Review updated HTSUS classifications for both steel and aluminum derivative products.
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Confirm declared values for steel and aluminum content, with separate reporting of non-metallic components.
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Implement smelt and cast reporting processes for aluminum entries.
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Audit FTZ admissions and ensure privileged foreign status is properly applied.
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Prepare for enforcement without drawback availability.
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