Additional Steel Derivative Tariff Inclusion Products
On August 15, 2025, U.S. Customs and Border Protection (CBP) issued formal guidance following the Department of Commerce’s expansion of Section 232 tariffs to include 407 additional steel derivative products, significantly widening the scope of items subject to duties.
Effective August 18, 2025, at 12:01 a.m. EDT, all covered goods entered for consumption, or withdrawn from warehouse for consumption, became subject to tariffs with no in-transit exemptions. CBP’s Cargo Systems Messaging Service (CSMS) bulletin clarified filing instructions: importers must report both the standard HTSUS classification and the appropriate Chapter 99 subheading, such as 9903.81.90 or 9903.81.91 for steel derivatives from most countries at a 50% ad valorem rate on the steel content, or 9903.81.97 and 9903.81.98 for UK-origin derivatives at a 25% rate. The expanded list of HTS codes covers a wide range of goods, from industrial items like knives, engines, lawn mowers, rail equipment, and transformers to consumer products such as furniture, appliances, paint, shampoo, and shaving cream—largely because of their steel or aluminum packaging or components. CBP emphasized that duties apply only to the steel or aluminum portion of the product, though in cases where the content is unclear, importers risk the duty being assessed on the full product value. The Bureau of Industry and Security (BIS) rejected 60 proposed codes due to overlaps with ongoing investigations but signaled that future inclusion rounds will continue, with the next submission window set for September 2025.
For importers, this expansion means immediate compliance obligations—auditing product lines, reviewing HTS classifications, and recalculating landed costs are critical steps to avoid penalties and supply chain disruptions. With the expansion now reaching into everyday consumer goods as well as industrial sectors, businesses should prepare for higher costs, monitor CBP bulletins closely, and develop strategies to manage tariff exposure going forward.
