On February 10, 2025, the President issued proclamations 10895 and 10896 on Adjusting Imports of Aluminum and Steel into the United States, under Section 232 of the Trade Expansion Act of 1962, imposing tariffs on imports of aluminum and steel and aluminum and steel derivative articles from all countries effective March 12, 2025.
Beginning March 24, 2025, shipments potentially subject to derivative reporting will be placed on HOLD if required details are not provided. This information is necessary to limit duty exposure, aid in compliance, and to tender accurate duty amounts.
Please use the attached spreadsheet or pdf to assist with reporting when submitting entry documents to Willson International.
Please note: the spreadsheet version has three tabs:
· Derivative reporting
· Aluminum derivative reference
· Steel derivative reference
If your product contains steel and/or aluminum derivatives, you must add the value of the content using the attached Declaration. This includes reporting the country of melt and pour for steel, and the primary, secondary smelt, and country of most recent cast for aluminum. Review the additional tabs on the Declaration form to determine if your tariff codes require this additional data.
Steel and Aluminum Declaration
Declaration for Steel and Aluminum content
Reporting Instructions for Duties Based on Steel Content
For new steel derivatives outside of Chapter 73, the 25% duty is to be reported based upon the value of the steel content.
If the value of the steel content is the same as the entered value or is unknown, the duty must be reported based on the entire entered value.
If there is no steel content but the article falls into one of the derivative tariff codes, you must note ‘no steel content’ for that line.
Melt and Pour Reporting Requirements
The reporting of the country of melt and pour is mandatory. To report the country of melt and pour, importers must use the ISO country of origin code for steel articles and derivative steel articles subject to Sec 232. For steel articles, importers must report where the steel was originally melted and poured. For steel derivatives, importers must report where the steel was originally melted or ‘OTH’ for other countries. For products melted and poured in the United States, importers must indicate ‘US’ as the country of melt and pour.
If the country of melt and pour is not reported per the above, duty could be assessed at 100% or more.
Reporting Instructions for Duties Based on Aluminum Content
For new aluminum derivatives not classified in Chapter 76, the 25% duty is to be reported based upon the value of the aluminum content.
If the value of the aluminum content is the same as the entered value or is unknown, duty must be reported based on the entire entered value.
If there is aluminum content but the article falls into one of the derivative tariff codes, you must note or ‘no aluminum content’ for that line.
Smelt and Cast Reporting Requirements
To report the primary country of smelt, secondary country of smelt, or country of most recent cast importers must report the ISO code on aluminum articles and derivative aluminum articles on all countries subject to section 232. If the imported product was smelted and cast in the United States, then the importer will report “US” for the country of smelt and “US” for the country of cast.
If the country of primary smelt and country of last cast is not reported per the above, duty could be assessed at 100% or more.