Important Updates on Section 232 Tariffs on Steel and Aluminum

In a Federal Register notice set to publish on August 19, the Bureau of Industry and Security (BIS) has announced that 407 new HTSUS subheadings will be added to the list of products covered by the Section 232 actions on steel and aluminum. These products will now be subject to 50 percent tariffs. These tariffs will be effective for products that are entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on August 18.

For those who need detailed information on the specific HTSUS subheadings affected, comprehensive lists are available.

The list for the aluminum tariff can be found at the bottom of the following page: CSMS # 65936615 - GUIDANCE: Section 232 Additional Aluminum Derivative Tariff Inclusion Products.

Similarly, the list for the steel tariff can be found here: CSMS # 65936570 - GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products

The Section 232 tariffs on steel and aluminum apply exclusively to the steel and/or aluminum content of the products in question. If a product contains both steel/aluminum and non-steel/non-aluminum components, the non-steel and non-aluminum content is subject to reciprocal tariffs. These reciprocal tariffs do not apply to the steel and aluminum content if it is already subject to Section 232 tariffs. However, other tariffs, such as antidumping and/or countervailing duties, Section 301 CN duties, and IEEPA Fentanyl duty, may still apply to products subject to Section 232 tariffs.

To avoid a 50% tariff on the entire product value for products with mixed composition, invoices must clearly indicate the value and weight (in kilograms) of the steel/aluminum content. This requires two lines per product on the invoice. Manufacturer’s specifications substantiating this information must be available, as customs may request this documentation. Without this information provided or if the value of the steel/aluminum content is unknown, the duty must be reported based on the entire product value.

There are no in-transit exceptions noted in the Federal Register, so these changes go into effect immediately for all new HTSUS subheadings on the steel and aluminum tariff lists. This means that any products currently in transit will also be subject to the new tariffs.

IFF, Inc is committed to keep you informed and monitor the situation for further updates. If there are any questions or further clarification needed, do not hesitate to reach out.