President Trump Increases Import Duties on Imports of Aluminum and Aluminum Derivative Products
Background
- Tariff Increase: Effective June 4, 2025, tariffs on certain aluminum articles and derivative aluminum articles imported into the United States will increase from 25% to 50% ad valorem under Section 232 of the Trade Expansion Act of 1962.
- Exemption for the UK: Products imported from the United Kingdom will remain at the previous tariff rate of 25% ad valorem.
- Effective Date: The new tariff rates will apply to goods entered for consumption or withdrawn from warehouse for consumption starting at 12:01 AM Eastern Daylight Time on June 4, 2025.
- Updates on Duty Rates: Importers should stay updated on duty rates, effective dates, and Section 232 duties, which are based on the value of aluminum content for imports classified in Chapter 76.
Guidance
- Effective Date: Starting from June 4, 2025, new duty rates will apply to aluminum articles and derivative aluminum products.
- Duty Rates:
- 50% Duty Rate: Applicable to aluminum products from all countries except the United Kingdom.
- 25% Duty Rate: Specific to products from the United Kingdom.
- HTSUS Headings:
- 9903.85.02/9903.85.12 (UK): Aluminum products, excluding certain derivative articles.
- 9903.85.04/9903.85.13 (UK): Derivative aluminum products listed in specific subdivisions, subject to Section 232 prior to March 12, 2025.
- 9903.85.07/9903.85.14 (UK): New derivative aluminum products classified in Chapter 76, subject to Section 232 on or after March 12, 2025.
- Special Cases:
- 0% Duty Rate: Applies to derivative aluminum articles smelted and cast in the United States under the HTSUS heading 9903.85.09.
- Further Duty Rates:
- For derivative aluminum articles entered for consumption on or after June 4, 2025:
- 50% Duty Rate: For products from all countries except the UK.
- 25% Duty Rate: For products from the UK, specifically on the value of the aluminum content.
- For derivative aluminum articles entered for consumption on or after June 4, 2025:
- Additional HTSUS Headings:
- 9903.85.08/9903.85.15 (UK): New aluminum derivative articles not classified in Chapter 76, with duties based on aluminum content value.
Reporting Instructions for Duties Based on Aluminum Content
- If the aluminum content value matches the entered value or is unknown, report under Chapter 99 based on the entire entered value.
- If the aluminum content value is less than the total entered value, report on two lines:
- First Line (Non-Aluminum Content):
- Use Ch 1-97 HTS (same HTS for both lines).
- Report the country of origin.
- Enter the total value minus aluminum content.
- State the total quantity of imported goods.
- Include other applicable duties (e.g., IEEPA tariffs).
- Second Line (Aluminum Content):
- Same Ch 1-97 HTS.
- Same country of origin.
- Report 0 for quantity on this line.
- Enter the value of aluminum content.
- Report Section 232 duties based on aluminum value.
- Include a second quantity in kilograms.
- First Line (Non-Aluminum Content):
- Duties for Aluminum from Russia:
- A 200% duty is enforced on aluminum products and derivatives from Russia. This applies if:
- The aluminum is smelted or cast in Russia.
- Report under HTS heading 9903.85.67 for aluminum products and 9903.85.68 for derivatives, both subject to the 200% duty.
- A 200% duty is enforced on aluminum products and derivatives from Russia. This applies if:
Smelt and Cast Reporting Requirements
- Importers must report the International Organization for Standardization (ISO) code for aluminum articles and derivative aluminum articles from countries subject to Section 232.
- Primary and Secondary Country of Smelt:
- Importers must indicate โYโ for the primary country of smelt and/or secondary country of smelt.
- Reporting โNโ for both is not permitted.
- Recycled Aluminum:
- If aluminum is solely made from recycled materials, report โYโ for the secondary country of smelt.
- The country of origin should be reported as the secondary country of smelt.
- Note: Aluminum made only from recycled materials is uncommon, and importers must provide manufacturing documents upon request.
- Derivative Aluminum Imports:
- If the country of smelt and cast is unknown, importers may report any country except the United States as a temporary measure.
- Post-summary corrections can be made to update the country of smelt or cast when accurate information is available.
- Country of Origin:
- If the product was smelted and cast in the United States, report โUSโ for both the country of smelt and the country of cast.
Exclusions and Drawback
- Importer-specific product exclusions for Section 232 duties will remain effective until either their expiration date or until the excluded product volume is imported, whichever comes first.
- No drawback will be available concerning the duties imposed, meaning importers cannot reclaim any duties paid on these products.
Foreign Trade Zone (FTZ)
- Aluminum Articles Duty Status: Aluminum articles, except those classified under “domestic status” as per 19 CFR 146.43, are subject to duties imposed by the Proclamation if admitted into a U.S. foreign trade zone (FTZ) post-Commerce certification date.
- Privileged Foreign Status: These articles can only be admitted under “privileged foreign status” as defined in 19 CFR 146.41, meaning they will incur applicable ad valorem rates of duty based on their HTS subheading classification.
- Effective Reporting Requirements: Starting from June 4, 2025, smelt and cast reporting requirements will apply to goods admitted into a U.S. FTZ and withdrawn for consumption, emphasizing the need for compliance among importers.
Application of Reciprocal Tariffs under EO 14257
- As of June 4, 2025, the non-aluminum content of articles is now subject to Reciprocal Tariffs under HTS 9903.01.25.
- Tariff Classification: The aluminum content, however, is not subject to Reciprocal Tariffs under HTS 9903.01.33 but is still subject to Section 232 duties.
Reporting Multiple HTS Numbers
- Importers must ensure that duties are correctly associated with the corresponding HTS numbers when submitting entry summary lines. For instance, if the entry is subject to HTS numbers 9903.85.02/9903.85.12(UK), the 25 percent duty must specifically be linked to these HTS numbers.
- No Combination of Duties: Duties across multiple HTS numbers on a single entry summary line cannot be combined. Each duty must be reported separately to avoid confusion and ensure compliance.
- Compliance Expectations: The Customs and Border Protection (CBP) agency expects full compliance from the trade community regarding the accurate reporting and payment of additional duties.
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