Section 232 Additional Steel Derivative (Ch 73) Tariff Inclusion
Products
Effective
Date: Aug 18, 2025 (12:01 a.m. EDT)
Authority:
Proclamation 10896 (Feb 10, 2025; 90 FR 11249) – Adjusting Imports of Steel
into the U.S.
Tariff
Impact:
Additional derivative steel products added to Annex I of HTSUS; technical corrections
under Annex II.
Applicable
to goods entered/withdrawn for consumption on or after Aug 18, 2025
·
Applies
to newly added steel derivatives under U.S.
Note 16 (subdivisions m, n, t, u).
·
Filers
must classify under both regular
HTSUS subheading and the relevant
Chapter 99 HTSUS number below:
1.
9903.81.90 – Derivative iron/steel products
(subdivision m, Ch. 73) – All
countries except UK
o 50% ad valorem duty (value of steel content).
2.
9903.81.91 – Derivative iron/steel products
(subdivision n, non–Ch. 73) – All
countries except UK
o 50% ad valorem duty (value of steel content).
o Also applies to goods admitted to FTZs
with privileged foreign
status (PFS) before Aug 18, 2025, but withdrawn after.
3.
9903.81.97 – Derivative iron/steel products
(subdivision t, Ch. 73) – UK
only
o 25% ad valorem duty (value of steel content).
4.
9903.81.98 – Derivative iron/steel products
(subdivision u, non–Ch. 73) – UK
only
o 25% ad valorem duty (value of steel content).
o Also applies to goods admitted to FTZs
with PFS
before Aug 18, 2025, but withdrawn after.
5.
9903.81.92 – Derivative steel/iron products
(subdivisions n or u) processed
abroad from U.S.-melted & poured steel – All countries (including UK)
o 0% duty.
o Also applies to FTZ goods with PFS before Aug 18, 2025,
but withdrawn after.
Reference:
CSMS #65236374
for steel content reporting instructions.
·
Non-steel
content:
Subject to HTS 9903.01.25
reciprocal tariffs.
·
Steel
content under Section 232:
Not
subject to reciprocal tariffs (HTS 9903.01.33).
·
Drawback: Not available for Section 232 steel
derivative duties.
·
Foreign
Trade Zones (FTZs):
o Newly added goods under “privileged
foreign status” before Aug 18 still covered when withdrawn after.
o Smelt/pour reporting obligations continue
for FTZ withdrawals.
·
Smelt
& Pour Reporting:
Importers must declare country
of melt & pour for all Section 232 steel products.
Action
for Importers & Brokers:
1.
Use
updated HTSUS 99-series
numbers from Aug 18, 2025.
2.
Correctly
allocate steel vs
non-steel content on entry lines.
3.
Report
country of melt & pour
per CSMS #65236374.
4.
Apply 50% (general) or 25% (UK)
duty rates as applicable.
5.
Apply 0% duty for eligible
U.S.-origin steel re-processed abroad.
6.
Ensure
FTZ entries are managed under privileged
foreign status rules.
GUIDANCE
The purpose
of this message is to provide guidance on adding additional steel derivative products
to Annex I of the Harmonized Tariff Schedule of the United States (HTSUS) under
Proclamation 10896.
BACKGROUND
On February
10, 2025, the President issued Proclamation 10896, “Adjusting Imports of Steel into
the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended
(19 U.S.C. 1862). This proclamation imposes
a 25 percent ad valorem tariff on certain imports of steel articles and derivative
steel articles from all countries, effective June 23, 2025. See 90 FR 11249 (March 5,
2025).
In Proclamation
10896, the President authorized and directed the Secretary of Commerce to publish
modifications to the HTSUS to reflect the amendments and effective dates in the
proclamation.
Effective
August 18, 2025, in accordance with “Adoption and Procedures of the Section 232
Steel and Aluminum Tariff Inclusions Process” the Commerce
Department will be adding additional steel derivative products to Annex I of the
HTSUS to be subject to Section 232 duties.
Further, Annex II makes technical corrections to the Harmonized Tariff Schedule
of the United States.
ENTRY FILING
INSTRUCTIONS
This guidance
provides instructions for importers, brokers, and filers on submitting entries to
U.S. Customs and Border Protection (CBP) on certain steel derivative imports, effective
with respect to goods entered for consumption, or withdrawn from warehouse for consumption,
on or after 12:01 a.m. Eastern Daylight Time on August 18, 2025. The following steel derivative products added
to subdivisions (m/n/t/u) of U.S. Note 16 of the Harmonized Tariff Schedule of the
United States (HTSUS) are subject to Section 232 duties.
Review the
attached steel HTS list to see the additional products (identified in bold) added
to the below Chapter 99 HTSUS:
Report the
Section 232 steel derivative duties applicable to goods classified in the eight-digit
subheadings and the 10-digit statistical reporting number listed in the attached
steel HTS list (hereinafter the “newly-added goods”) under the following Chapter
99 HTSUS numbers:
See CSMS # 65236374 for steel content reporting instructions.
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.
Consult the
Section 232 Tariffs on Steel and Aluminum Frequently Asked
Questions (FAQs) for additional guidance, including on reporting country of melt
and pour, determining the value of steel content and reporting requirements on goods
subject to both steel and aluminum duties.
Summary of Section 232 Chapter 99 HTSUS classifications
is attached.