Aluminum and Steel Derivatives Lists for Section 232 Tariffs with HS Codes

The White House published the annex listing aluminum derivatives that will face additional Section 232 tariffs of 25%, as well as the annex with the steel derivatives that will face 25% tariffs (except derivatives from Turkey, which will see 50% tariffs. Turkey’s exports of the original steel products covered by Section 232 are not subject to 50% tariffs.). Derivatives are defined as products made from steel or aluminum in whole or in part.

The original 232 HS code List from 2018
New lists below issued on February 14 2025 for the additional
Derivative Steel HS code list.
Steel Aluminum HS code list.
Please review the lists to see if your products are affected.

For aluminum derivatives, 18 of the tariff lines are in Chapter 76, which means the entire value will be tariffed; the other 104 are in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96, and only the aluminum content in those goods will face the tariffs.

For steel derivatives, 155 items are in chapter 73; additional items are listed in Chapters 84, 85 and 94 and duties will only be applied to the steel content in these items. The items in those chapters include bulldozer blades, parts of escalators and elevators, backhoe and front-loader attachments, plows, metal furniture including steel shelving, modular steel building units, brass lighting fixtures and other lighting fixtures of steel.

Exemptions -If the steel in the product was melted and poured in the U.S., or the aluminum was smelted and cast in the U.S., then exported to the country that made the finished good, Section 232 duties would not be applied.

Steel and Aluminum Content -The notice instructs importers of derivatives of either metal to provide to CBP “any information necessary” to identify the metal content in the product. “CBP is hereby authorized and directed to publish regulations or guidance implementing this requirement as soon as practicable.” Specific documentation for this requirement was not mentioned but will be announced at a later date.

Effective Date for Derivatives–The notice does not include an effective date for the additional duties on the derivatives, but says there will be another public notice on when the tariffs will be applied, once systems are in place to collect them.

The Department of Commerce was given 90 days to advise that an adequate system is in place to “fully, efficiently and expediently process and collect the tariffs” for the covered articles. There will be public notification before the tariffs are due on the derivative items.

In an additional note, within 90 days after the date of the original proclamations issued on February 11th, the Secretary shall establish a process for including additional derivative steel articles. This process shall provide for including additional derivative steel and aluminum articles at the request of a producer in the US of a steel or aluminum article or derivative steel article, or an industry association in the US representing one or more such US producers, where the request establishes that imports of a derivative steel or aluminum article have increased in a manner that threatens to impair the national security. When the Secretary receives such a request from a domestic producer or industry association, the Secretary shall issue a determination regarding whether or not to include the derivative steel or aluminum article or articles within 60 days of receiving the request.

The duties for the original established Section 232 tariff codes from 2018 will begin on March 12, 2025 as announced on February 11^th. That list is attached.

We will keep you informed of any future announcements as they become available.

Full Publication References
Full text of the Published Derivatives Lists for Steel and Aluminum

Proclamation of Section 232 Duties for Aluminum on All Countries

Proclamation of Section 232 Duties on Steel on All Countries

February 12, 2025

President Trump has issued proclamations to the following changes to the steel and aluminum tariffs will be effective as of 12:01 a.m. EDT on March 12.

– The 25 percent Section 232 tariff on steel and steel derivative articles will be extended to imports from all countries.

– The 10 percent Section 232 tariff on aluminum and aluminum derivative articles will be increased to 25 percent and extended to imports from all countries.

– These tariffs will be extended to additional derivative articles (which will be identified in annexes to the proclamations that had not been published at press time, and a process for further expansion will be established), with exceptions for those processed in another country from steel articles melted and poured, or aluminum articles smelted and cast, in the U.S.

– The alternative agreements for Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, Ukraine, and the UK will be terminated.

– All existing general approved exclusions from the tariffs will be terminated (though granted product exclusions will remain in effect until their expiration date or until their excluded volume is imported, whichever occurs first, and the process for requesting exclusions has been terminated as of Feb. 10).

However, both proclamations include language suggesting that tariffs on derivative articles will not take effect until the Department of Commerce provides public notification that adequate systems are in place to fully, efficiently, and expediently process and collect associated tariff revenue, though it is unclear which articles this suspension will apply to.  

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

Click Here for a list of current HS codes covered under Section 232. This list will be updated prior to March 12 with additional products. The additional products have not yet been announced.

The proclamations did not address low value shipment exemptions under Section 321 or Type 86 Entries (de minimis). This will be addressed and clarified in future publications.

Once further information is available, we will be posting the updates to our website as well as notifying you through email.