Updated Guidance: Section 232 Additional Steel Derivative Tariff Inclusion Products
This article is a summary of CSMS # 65936570 – GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products, along with a download file containing a listing of the updated HTS Codes.
To review the complete document, please click on the following link:
CSMS # 65936570 – GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products
Background
- New Tariff Rate: A 25% ad valorem tariff will be imposed on certain steel articles and derivative steel products from all countries
- Effective Date: The tariffs take effect on June 23, 2025
- Legal Authority: The proclamation operates under Section 232 of the Trade Expansion Act of 1962, giving the President broad powers to adjust imports for national security reasons
- Commerce Department Role: The Secretary of Commerce has been authorized to modify the Harmonized Tariff Schedule of the United States (HTSUS) to implement these changes
- Expanded Coverage: Starting August 18, 2025, additional steel derivative products will be added to the tariff list through the Commerce Department’s Section 232 Steel and Aluminum Tariff Inclusions Process
- Technical Updates: The proclamation includes technical corrections to the current tariff schedule to ensure proper implementation
Entry Filing Instructions
U.S. Customs and Border Protection has announced new Section 232 duties on steel derivative products, affecting goods entered for consumption starting at 12:01 a.m. Eastern Daylight Time on August 18, 2025.
Most Countries (excluding UK):
- 50% ad valorem duty on steel content value
- Applies to products under HTSUS codes 9903.81.90 and 9903.81.91
- Covers derivative iron/steel products in subdivisions (m) and (n)
United Kingdom Only:
- 25% ad valorem duty on steel content value
- Applies to products under HTSUS codes 9903.81.97 and 9903.81.98
- Covers UK derivative iron/steel products in subdivisions (t) and (u)
All Countries (including UK):
- 0% duty for derivative products processed from U.S.-melted steel
- Applies under HTSUS code 9903.81.92
- Must prove steel was originally melted and poured in the United States
- Duty calculation: Based on the value of steel content, not the entire product value
- Product coverage: Newly added steel derivatives listed in bold on the attached HTS list
- Foreign trade zones: Products admitted with “privileged foreign status” before August 18, 2025, are still subject to new duties when withdrawn for consumption after that date
Application of Reciprocal Tariffs under EO 14257
The non-steel content of an article reported on a separate line per the instructions identified in CSMS 65236374, is subject to Reciprocal tariffs under HTS 9903.01.25. The steel content subject to Section 232 duties is not subject to Reciprocal tariffs under HTS 9903.01.33.
Drawback
No drawback shall be available with respect to the duties imposed pursuant to Proclamation 10896.
Next Steps
- Review the attached steel HTS list to identify affected products
- Consult CSMS #65236374 for detailed steel content reporting instructions
- Ensure proper classification under the correct Chapter 99 HTSUS numbers
- Calculate duties based on steel content value, not total product value
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
