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President Trump Increases Import Duties on Imports of Steel and Steel Derivative Products

06/04/2025 | Dominion Customs Consultants Inc | , ,

CSMS # 65236374 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products

Background

  • Updated Guidance: As of June 3, 2025, the U.S. President issued a proclamation adjusting import duties on steel and derivative products.
  • Tariff Increase: The Section 232 tariffs on certain steel imports have increased from 25% to 50% ad valorem for most countries.
  • Effective Date: These new tariffs will apply to goods entered for consumption or withdrawn from warehouses starting 12:01 AM EDT on June 4, 2025.
  • Exceptions: The United Kingdom’s steel products will continue to be subject to the previous tariff rate of 25% ad valorem.

Guidance

  • Effective Date: Starting from 12:01 a.m. Eastern Daylight Time on June 4, 2025, new tariff rates will be enforced for steel articles and derivative steel articles.
  • Tariff Rates:
    • A 50% duty rate will apply to steel products from all countries, except the United Kingdom, which will incur a 25% duty rate.
    • Specific HTSUS headings for the UK include:
      • 9903.81.87/9903.81.94: Iron or steel products (excluding derivative articles).
      • 9903.81.88/9903.81.95: Iron or steel products admitted to a U.S. foreign trade zone under “privileged foreign status” before June 4, 2025.
      • 9903.81.89/9903.81.96: Certain existing derivative iron or steel products.
      • 9903.81.90/9903.81.97: New derivative iron or steel products classified in Chapter 73.
  • Special Conditions:
    • For derivative steel articles from all countries, a 0% duty rate applies if the steel was melted and poured in the United States, under HTSUS heading 9903.81.92.
    • This includes products processed in other countries from U.S. melted steel and those admitted to a foreign trade zone before the effective date.
  • Additional Considerations:ucts:
    • Iron or Steel Products (UK):
      • 9903.81.87/9903.81.94: Iron or steel products (excluding derivative articles).
      • 9903.81.88/9903.81.95: Iron or steel products (excluding derivative articles) admitted to U.S. foreign trade zones before June 4, 2025.
      • 9903.81.89/9903.81.96: Certain existing derivative iron or steel products subject to Section 232 prior to March 12, 2025.
      • 9903.81.90/9903.81.97: Certain new derivative iron or steel products classified in Chapter 73 subject to Section 232 on or after March 12, 2025.
      • 9903.81.93/9903.81.99: Existing and new derivative steel products admitted to U.S. foreign trade zones before June 4, 2025.

Reporting Instructions for Duties Based on Steel Content

  • New Policy on Steel Derivatives: The recent regulations apply to new steel derivatives outside of Chapter 73 and all steel articles classified in Chapter 73, both subject to Section 232 steel duties.
  • Tariff Rates:
    • A 50% duty is applicable for most products.
    • A reduced 25% duty applies specifically to products from the United Kingdom.
  • Reporting Guidelines:
    • Duties must be reported under Chapter 99 based on the value of the steel content.
    • If the steel content value is unknown or matches the entered value, report using one entry summary line.
    • If the steel content value is less than the total entered value, report on two lines:
      • First Line (Non-Steel Content):
        • Use Ch 1-97 HTS (same HTS for both lines).
        • Report the country of origin.
        • Include the total entered value minus the steel content value.
        • Report the total quantity of imported goods.
        • Include other applicable duties (IEEPA tariffs, antidumping, countervailing duties).
      • Second Line (Steel Content):
        • Same Ch. 1-97 HTS and country of origin as the first line.
        • Report 0 quantity for the Ch. 1-97 HTS.
        • Report the value of the steel content.
        • Include Section 232 duties based on the steel content value with the Chapter 99 HTS.
        • Report the quantity of steel content in kilograms with the Chapter 99 HTS.
        • Include all other applicable duties.
  • Effective Date: Importers should be aware of the immediate implementation of these guidelines to ensure compliance.
  • Affected Countries: This policy impacts all countries exporting steel products, with specific attention to the UK due to the reduced tariff rate.

Melt and Pour Reporting Requirements

  • Mandatory Reporting: Importers must report the country of melt and pour for both steel and steel derivatives.
  • ISO Code Requirement:
    • For steel articles, importers must indicate the ISO code where the steel was originally melted and poured.
    • For steel derivatives, the ISO code must reflect where the steel was originally melted or marked as โ€œOTHโ€ for other countries.
  • Products Melted in the U.S.: Importers must specify โ€œUSโ€ as the country of melt and pour for products melted and poured within the United States.

Exclusions and Drawback

  • Importer-Specific Product Exclusions: Active in the Automated Commercial Environment (ACE) for Section 232 duties will remain effective until their expiration date or until the excluded product volume is importedโ€”whichever comes first.
  • No Drawback Available: Importers should note that no drawback will be available regarding the duties imposed.

Foreign Trade Zone (FTZ)

  • Effective Dates:
    • March 12, 2025: New admissions into U.S. FTZs must comply with the “privileged foreign status” requirement.
    • June 4, 2025: Classification guidelines for steel and derivative products will take effect for goods entering after this date.
  • Tariff Percentages:
    • Different HTS classifications will apply to various types of steel products:
      • 9903.81.88/9903.81.95: Iron or steel products
      • 9903.81.93/9903.81.99: Iron or steel derivative products (with specific exceptions).
  • Affected Countries: This regulation impacts all countries exporting steel articles to the U.S., emphasizing the need for compliance among importers and customs brokers.

Application of Reciprocal Tariffs under EO 14257

Reporting Multiple HTS Numbers

  • Duty Reporting Requirement: For entries that include multiple HTS numbers, CBP mandates that duties must be accurately assigned to the corresponding HTS.
  • Example Clarification: If an entry is subject to HTS 9903.81.87, the associated 25% duty must be reported specifically under that HTS during ACE transmission and on the printed 7501 form.
  • No Combining Duties: Duties cannot be merged with those reported under different HTS numbers on the same entry summary line. Each HTS must reflect its respective duty independently.
  • Enforcement Expectations: CBP anticipates full compliance from the trade community regarding the accurate reporting and payment of additional duties. Non-compliance will lead to enforcement actions.

Should you or your organization have any questions,

please do not hesitate to contact your Dominion Customs Consultants representative,

or feel free to reach us here

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