ARTICLE
19 August 2025

BIS Adds To Section 232 Steel, Aluminum Derivatives Lists

CM
Crowell & Moring LLP

Contributor

Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
The Bureau of Industry and Security (BIS) will include multiple additional items as steel and aluminum derivative products, which will be subject to the Section 232...
Worldwide International Law

The Bureau of Industry and Security (BIS) will include multiple additional items as steel and aluminum derivative products, which will be subject to the Section 232 measures on their steel and aluminum content.

The BIS's notice will be published in the Federal Register on August 19, 2025, with the effect of the measure for the additional derivative products, entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August 18, 2025. Only the value of the steel or aluminum content in these derivative products will be subject to the Section 232 tariff, as with the previous list of derivative products.

The notice identifies 407 HTSUS codes as part of the first cycle of the Section 232 Inclusions Process, which started in May 2025. Interested persons may request the inclusion of additional articles incorporating steel and aluminum to Section 232 measures. Such requests can be submitted to the BIS during a two-week period at the beginning of May, September, and January.

The derivative products include various articles containing steel or aluminium, such as air compressors, cables, steel mill rolls, fluid end blocks of hydraulic power pumps, and wind towers as part of a wind-powered electric generating set with nacelles and/or rotor blades. In addition, the measure covers household items, including silverware, knives, forks, spoons, bar stools with metal frames or dining chairs with aluminum frames, dumbbells and kettlebells, as well as filled aerosol packages (i.e., metal containers), e.g. those containing foodstuffs, lubricants, spray paint, perfume, sunscreen, or deodorants. Some tools are also affected, including chain saws, electric hand saws, gas-powered leaf blowers, gas-powered string trimmers, multi-tools, grinders and sanders. And many more. The entire list can be consulted at  this link.

The steel derivative articles falling under subdivisions (m/n/t/u) of U.S. Note 16 of the HTSUS are subject to 50 percent duty for all countries, other than the UK, and 25 percent in the case of the UK. In cases where the derivative iron or steel products, subdivisions (n) or (u), were processed in another country from steel articles that were melted and poured in the United States, they do not attract the Section 232 duty. See the relevant CBP  Guidance.

Similarly, aluminum derivative articles falling under subdivisions (j/k/r/s) of U.S. Note 19 of the HTSUS are subject to 50 percent duty for all countries, other than the UK, and 25 percent in the case of the UK. Derivative aluminum products listed in subdivisions (j), (k), (r), or (s), which were processed in another country from aluminum articles smelted and cast in the United States, are subject to a 0 percent duty. See the relevant CBP  Guidance on the matter.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More