On June 3, 2025, the Whitehouse announced an increase to the Section 232 Steel and Aluminum tariffs for most countries, and Customs and Border Protection (CBP) provided updated guidance for properly reporting the tariffs for accurate duty assessment.
What changes were made to the tariffs?
- Tariff Increase – On June 3, 2025, in a Presidential Proclamation, the Whitehouse announced that effective on entries made on or after June 4, 2025, the Section 232 rate of duty for Steel and Aluminum Articles and Derivative products increased from 25% to 50% for all countries except the UK, Russia/Belarus, and the U.S.
- The rate of duty for the UK will remain at 25% for both Steel and Aluminum, with a possible increase or quotas starting on July 9, 2025, depending on the status of the U.S.-UK Economic Prosperity deal
- Aluminum from Russia/Belarus remains at 200%.
- Value of Steel/Aluminum Content – For Steel (except for Chapter 72)or Aluminum articles and derivatives, the 50% (25% UK) duty is only assessed on the reported value of the steel and/or aluminum content.
- NEW: Steel Derivative products in Chapter 73, and Aluminum Derivative products in Chapter 76 now allow reporting of the value of the steel and/or aluminum content for duty calculation. This might result in duty savings.
- If the steel and/or aluminum content value cannot be broken out, the duties will be assessed on the full value of the imported product.
- Reciprocal Tariffs – Previous to this announcement, the Reciprocal tariff (currently 10%) was exempt if any amount of Section 232 tariff was assessed; however, now the Reciprocal tariff will also be assessed on the value of the non-steel or non-aluminum content.
- The Importers will want to be able to break out the content value as the goods will be subject to 50%/25% UK on the steel/aluminum AND 10% Reciprocal tariff on the non-steel/aluminum content. Without the value breakout, the 50%/25% UK will be assessed on the full value of the product.
- Aluminum Derivatives Country of Smelt & Cast – The country of Smelt and Cast for Aluminum Derivatives must be reported. Previously, if unknown CBP allowed the country of origin of the finished good to be reported with the standard Section 232 duty rate applied. As of June 28, 2025, if country of Smelt and cast is not known, Importers must report (Unknown) “UN” as the ISO country code for cast & smelt and will automatically be assessed the 200% Section 232 tariff rate.
- Importers must be able to substantiate the country of Smelt and Cast reported if other than unknown.
- Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual country(ies)
- Effective June 23, 2025, additional products have been added to the Steel Derivatives list including household appliances. (see below)
Best Practices – What do Importers need to do?
- Now that importers have the ability to report the steel or aluminum content for all HTS#s under 232 and pay 50% on the steel or aluminum content and 10% reciprocal duties (for most countries) on the value of the non-steel or aluminum content, it is in your best interest to provide the value breakdown. This requires having documentation to substantiate the value content breakdown.
- Work with your suppliers to determine, and be able to declare, the country of smelt and cast for Aluminum Derivatives. If this is unknown at the time of entry, the goods will be subject to 200% duties.
- Inform your suppliers of the importance of providing this detail, and ensure it is properly reported when you receive a copy of our 7501 (Customs Entry)
- See the Aluminum Content and Steel Content forms for details required for reporting to CBP.
- As noted in the Presidential Fact Sheet, President Trump is cracking down on false import declarations by requiring strict reporting of steel and aluminum content, with tough penalties like fines or loss of import rights for violators.
- Audit your customs entry (7501) when received to confirm that details were reported properly. Notify our office immediately if you have any questions.
Details of the New Reporting Requirements
Effective on entries made on or after June 4, 2025, additional HTS#s will be required to apply the increased tariffs, with separate provisional HTS#s for the UK. The tariff will only be assessed on the value of the Steel and/or Aluminum content only.
Provisional HTS#s for Reporting Section 232 Aluminum Articles and Derivatives:
- 9903.85.02 (50%) and 9903.85.12 (25% UK): Aluminum products except derivative articles listed in subdivisions (g)/(o).
- 9903.85.04 (50%) and 9903.85.13 (25% UK): Derivative aluminum products listed in subdivisions (i)/(q) (existing aluminum derivative articles subject to Section 232 prior to March 12, 2025).
- 9903.85.07 (50%) and 9903.85.14 (25% UK): Derivative aluminum products listed in subdivisions (j)/(r) (new aluminum derivative articles classified in Chapter 76 subject to Section 232 on or after March 12, 2025).
- 9903.85.08 50%) and 9903.85.15 (25% UK): Derivative aluminum products listed in subdivisions (k)/(s) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232)
- 9903.85.09 (0%) All countries – Derivative aluminum articles listed in subdivision (j) or (k) (new derivative aluminum articles), where the derivative aluminum products were processed in another country from aluminum articles that were smelted and cast in the United States.
- 9903.85.67 Aluminum Products / 9903.85.68 Aluminum Derivatives (200%) – Products of Russia OR Derivative products where the country of Smelt and Cast are Unknown (UN).
Provisional HTS#s for Reporting Section 232 Steel Articles and Derivatives:
- 9903.81.87 (50%) and 9903.81.94 (25% UK): Iron or steel products (except derivative articles)
- 9903.81.89 (50%) and 9903.81.96 (25% UK): Certain derivative iron or steel products (existing steel derivative articles subject to Section 232 prior to March 12, 2025).
- 9903.81.90 (50%) and 9903.81.97 (25% UK): Certain derivative iron or steel products (new steel derivative articles classified in Chapter 73 subject to Section 232 on or after March 12, 2025).
- 9903.81.91 (50%) and 9903.91.98 (25% UK): Derivative iron or steel products (new steel derivative articles not classified in Chapter 73 subject to Section 232)
- 9903.81.92 (0%): Certain derivative steel or iron products where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States.
Section 232 Resources:
June 3, 2025 Presidential Proclamation – Adjusting Imports of Aluminum and Steel into the U.S.
June 3, 2025 Fact Sheet: President Donald J. Trump Increases Section 232 Tariffs on Steel and Aluminum
The subject Steel Articles and Derivatives are provided in the HTS list in the June 3, 2025, CSMS# 65236374 and June 9, 2025, CSMS# 65289012.
The subject Aluminum Articles and Derivatives are provided in the HTS list in the June 3, 2025, CSMS# 65236645 and the June 9, 2025, CSMS# 65288784
Additional Household Products to Steel Derivative List: CSMS # 65405824 – GUIDANCE: Section 232 Additional Steel Derivative Products
CBP Trade Remedies – Section 232
CBP Section 232 FAQs