On February 14, 2025, the Trump Administration released a list of derivative products that are subject to 25% steel and aluminum tariffs under Section 232, except for derivative aluminum products of Russia origin which are subject to 200% ad valorem duty rate.
Duties on the newly listed derivative steel or aluminum articles are postponed until “public notification by the Secretary of Commerce, that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue on covered articles.”
For derivatives classified in Chapter 73 or 76, the 25% tariff will apply to the full product value. For derivatives classified outside of Chapter 73 or 76, the 25% tariff will only apply to the value of the steel or aluminum content, not the entire product.
We expect future notice that will specify a method for calculating the value of the steel or aluminum content.
Importers will have to provide U.S. CBP with information on the steel or aluminum content in these products. Additional derivative products may be identified in the future, although it is not clear yet how steel and aluminum content will be determined or reported.
Exceptions from the 232 duties:
• For steel – derivative steel articles processed in another country from steel articles that were melted and poured in the United States
• For aluminum – derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States
The formal notices were scheduled and have been published in the Federal Register on February 18, 2025.
Derivative Products:
Steel:
Nearly all of Chapter 73 (e.g., gazebos, canopies)
Steel furniture (9403.20.00)
Parts of lighting (9405.99.40)
Stoves, ranges, barbecues, and parts (7321)
Steel cookware
Aluminum:
Certain household articles
Aluminum furniture (9403.20.00)
Aluminum doors, windows, and frames (7610.10.00)
Parts for electric water heaters, hair dryers, etc. (8516.90.8050)
Some exercise and sporting equipment (9506, 9507)
Basis: Proclamations of February 10; Section 232 of the Trade Expansion Act of 1962; 3 U.S.C. 301; 19 U.S.C. 2483
Country: All (some exceptions may be negotiated)
The specific HTS subheadings are available for steel and aluminum.
A.N. Deringer, Inc. will continue to post Trade Alerts and update our New Trade Landscape page as new policies and relevant tariff information becomes available.
