Recent Presidential proclamations have introduced new tariffs for aluminum and steel articles, as part of a 25% tariff proposal effective March 12, 2025. Additionally, annexes published in the Federal Register set forth details for tariffs on derivative articles. You can find the relevant Federal Register notices here:
Federal Register: Adjusting Imports of Aluminum Into the United States
Federal Register: Adjusting Imports of Steel Into the United States
Understanding Derivatives and Their Impact
It is crucial to understand what constitutes a derivative and how these tariffs may affect your imported products. Derivatives are goods that contain components made from steel or aluminum but are not in their primary form. These articles are further down the production process and are considered by-products or secondary products made from the original material.
For aluminum derivatives not classified in Chapter 76 of the Harmonized Tariff Schedule, only the aluminum content is subject to Section 232 tariffs. Similarly, for steel derivatives not classified in Chapter 73, only the steel content is subject to Section 232 tariffs.
Recommendations for Compliance
Until more information is available on how these tariffs will be applied, we recommend that you:
- Review the steel and aluminum content in your products classified under the derivative tariff codes.
- Document the material content and maintain detailed records.
Additional guidance on reporting steel or aluminum content in derivative items will be forthcoming.