50% Section 232 Tariffs on 407 New Steel and Aluminum Derivatives Take Effect Aug. 18 – CBP Guidance Available
Trade Update • Aug. 15, 2025
Key Points
- Aug. 18, 2025 – 50% Section 232 tariffs expand to 407 new steel and aluminum derivative HTSUS subheadings.
- No transit exemption – Applies to all entries on or after 12:01 a.m. ET.
- Steel coverage – Adds products across 17 HTS chapters, including automotive parts.
- Aluminum coverage – Adds products across 15 HTS chapters.
- Technical corrections – HTS code replacements and clarifications issued.
- Requests rejected – 60 subheadings denied due to existing investigations.
- CBP steel guidance – updated list posted; tariffs stack; exclusions/quotas must match HTS.
- CBP aluminum guidance – updated list posted; tariffs stack; exclusions/quotas must match HTS.
- No retroactivity – Goods in transit not exempt.
- Next inclusion rounds – September 2025 and January 2026.
he Department of Commerce has confirmed that, starting at 12:01 a.m. Eastern Time on August 18, 2025, 407 new steel and aluminum derivative products will be subject to the existing 50% Section 232 tariffs via the ‘Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process’.
This major expansion follows the conclusion of the first formal inclusion process under the Section 232 steel and aluminum tariff rules. U.S. Customs and Border Protection (CBP) guidance on implementation is now available with the CBP Guidance section below.
50% Tariffs Effective Aug. 18 — No Transit Exemption
According to Commerce’s Aug. 15 notice, the expanded list of tariffed items will apply to all covered products entered for consumption or withdrawn from warehouse for consumption on or after the effective time. There will be no exception for goods already in transit as of that date. The changes are the direct result of the Section 232 tariff inclusion process initiated in May 2025. These actions add significant coverage across multiple Harmonized Tariff Schedule (HTS) chapters.
New HTSUS Coverage for Steel and Aluminum Derivatives
For steel derivatives, the new subheadings include products in HTS Chapters 4, 21, 27, 28, 29, 30, 32, 33, 34, 35, 38, 39, 72, 73, 76, 82, 83, 84, 85, 86, 87, and 94.
For aluminum derivatives, additions cover products in Chapters 4, 21, 27, 29, 30, 32, 33, 34, 35, 37, 38, 73, 76, 83, 84, 85, 87, and 94.
One example is HTSUS 8708.99.81, a catch-all provision for certain auto parts, which is now included under the steel derivative tariff list. Other automotive subheadings within Chapter 87 have also been added.
Technical Corrections to the HTSUS
The Aug. 15 notice also makes a series of technical amendments to the HTSUS:
Replacing subheading 9401.99.9081 in the aluminum derivatives list with 9401.99.9030 and 9403.99.9070.
Replacing 7302.90.00 in the steel derivatives list with the six-digit subheading 7302.90.
Clarifying that non-steel and non-aluminum content of otherwise covered goods remains subject to reciprocal and other applicable tariffs.
Products Not Covered
CBP Guidance
CBP has confirmed it will begin collecting the 50% ad valorem Section 232 duties on all covered steel and aluminum derivative goods under the new HTSUS subheadings effective with entries on or after August 18, 2025.
CSMS # 65936570 – GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products
CSMS # 65936615 – GUIDANCE: Section 232 Additional Aluminum Derivative Tariff Inclusion Products
The guidance outlines the following:
Filing requirements: Importers and brokers must report the correct Chapter 99 subheading in addition to the regular HTS classification on CBP entry summaries. Failure to include the appropriate Chapter 99 provision will result in rejection of the entry and may delay cargo release.
HTS Lists:
Updated List of Steel HTS Subject to Section 232 Duties (50% Ad Valorem) can be accessed here.
Update List of of Aluminum HTS Subject to Section 232 Duties (50% Ad Valorem) can be accessed here.
Applicability: The Section 232 tariff is in addition to any other applicable duties, taxes, fees, or trade remedies (e.g., antidumping/countervailing duties, Section 301 tariffs, or retaliatory tariffs).
No retroactivity or in-transit exemption: CBP will assess duties based solely on the entry date or withdrawal date for consumption. Goods already shipped but arriving after 12:01 a.m. ET on Aug. 18 will not be exempt.
Quota and exclusion treatment: Current product exclusions and quota-based exemptions under Section 232 remain applicable, but only if an exclusion is approved for the specific derivative product HTSUS classification.
CBP advises the trade to update internal classification databases, broker instructions, and entry filing templates in advance of the effective date to prevent clearance delays.
Next Inclusion Rounds
Commerce plans to conduct inclusion request periods three times per year. The next window opens in September 2025, followed by another in January 2026. Memoranda explaining the rationale for all decisions in this round are available in the public docket.
The information presented is general in nature, and is not intended to constitute legal advice with respect to any event or occurrence, and may not be considered as such. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information. Due to the complexity of Customs Regulations, valuations are based on information currently available and should not be considered binding, we recommend obtaining National Customs Rulings in areas of uncertainty.
How GHY Can Help?
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