Effective Today August 18, 2025

On August 15, 2025, the Trump Administration greatly expanded the list of goods subject to 50% tariff included within Section 232 Aluminum and Steel duties. This is a significant development that U.S. importers should take note of, since the new list of HTS codes now includes a large number of products previously not considered steel or aluminum derivatives. These duties are now required (August 18, 2025), and the provision does not include exceptions for goods in transit.

As noted by attorney Michael Roll:

“Many of these new HTS provisions would not normally be considered aluminum or steel derivative products … at least not by any reasonable understanding of those words. For example… the list of goods now subject to the aluminum and steel tariffs include items as diverse as dairy products (0402), food preparations (2106), petroleum oils (2710), and certain chemicals, etc. While the 50% tariff will only apply to the aluminum/steel aspects of these goods (which will presumably be just certain aluminum and steel packaging or container type materials), it shows just how broad this administration intends to throw its tariff net”.

Roll also states:

“Importers will recall that earlier this year the Trump Administration significantly expanded the list of products considered to be “steel derivative” and “aluminum derivative” products. The historic expansion of the 232 tariffs on aluminum and steel derivative products was only the beginning of the tariff nightmare for importers and brokers. The White House also allowed private parties to petition the Department of Commerce to include more products as aluminum and steel derivative products.

Under the “inclusion” process, the Department of Commerce created a process where every May, September and January, it will open up a two (2) week submission window to allow companies to ask for additional products to be included as aluminum or steel derivative products subject to the 50% tariff. The public will then have 2 weeks to review and comment on such proposals and Commerce will act on the petitions and comments within 60 days. See here for the relevant Federal Register notice.

On May 1, 2025, Commerce opened the first submission window. Over 50 companies asked Commerce to include hundreds of additional HTSUS classifications as aluminum and steel derivative products. On May 20, 2025, Commerce posted the petitions to regulations.gov, thereby starting the 14 day window for importers and the public to comment. The deadline for submitting comments was June 4, 2025. Friday’s announcement represents the culmination of this first inclusion process. Next month, another window will open for parties to request even further expansion of the aluminum and steel tariff coverage.”

To further aid our customers and partners, Deringer has compiled the government’s list of additional products into a user-friendly Excel file.  The Unofficial New Expanded Section 232 Derivative List of August 15, 2025 may be downloaded from our Forms page.

Source:  Michael Roll, Roll & Harris LLP

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.