Updated Guidance on U.S. Import Duties for Steel, Aluminum, and Derivative Products
Trade Update • March 12, 2025
he U.S. Customs and Border Protection (CBP) has released guidance on the implementation of new tariffs on import duties for steel, aluminum, and their derivative products. Effective March 12, 2025 a 25% tariff will apply to all steel, aluminum and their derivatives imports into the United States.
Steel and Derivatives
Applicable duty to various classifications of steel and derivative steel articles under the Harmonized Tariff Schedule of the United States (HTSUS) is as follows:
- 9903.81.87: Iron or steel products listed in subdivision (j) (excluding derivative articles) – 25% duty.
- 9903.81.88: Iron or steel products (except for derivative articles) listed in subdivisions (l), (m), and (n) that are admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025 – 25% duty.
- 9903.81.89: Derivative iron or steel products listed in subdivision (l) (existing steel derivative articles subject to Section 232) – 25% duty.
- 9903.81.90: Derivative iron or steel products listed in subdivision (m) (new steel derivative articles classified in Chapter 73 subject to Section 232) – 25% duty.
- 9903.81.91: Derivative iron or steel products listed in subdivision (n) (new steel derivative articles not classified in Chapter 73 subject to Section 232). Import duty is based on the value of the steel content – 25% duty.
- 9903.81.92: Derivative steel or iron products listed in subdivisions (m) or (n) (new derivative steel articles) where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States – 0% duty.
- 9903.81.93: Derivative iron or steel products listed in subdivisions (l) and (m) (existing derivative steel products and new derivative steel products in Chapter 73) admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025 – 25% duty.
Steel Content Reporting
For steel derivative articles outside of Chapter 73, the 25% duty is to be reported with HTS 9903.81.91 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 under HTS 9903.81.91 based on the entire entered value, and report on only one entry summary line.
In the case where the value of the steel content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-steel content while the second line will represent the steel content. Each line should be reported in accordance with the below instructions.
Non-Steel content, first line:
- Ch 1-97 HTS, this same HTS must be reported on both lines.
- Country of origin, same must be reported on both lines.
- Total entered value of the article less the value of steel content.
- Report the total quantity of the imported goods.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Steel content, second line:
- Same Ch. 1-97 HTS reported on the first line.
- Same country of origin reported on the first line.
- Report 0 for quantity for the Ch. 1- 97 HTS.
- Report the value of steel content.
- Report the Section 232 duties based on the value of steel content with HTS 9903.81.91.
- Report a second quantity (of the steel content) in kilograms with the HTS 9903.81.91.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Detailed Reporting for Goods Under Chapter 98 for Steel
- Goods claimed under a provision of Chapter 98 that are subject to additional duties will still be eligible under Chapter 98 provisions and must comply with U.S. Customs and Border Protection (CBP) regulations.
- Duties under subheading 9802.00.60 will be assessed based on the full value of the imported article rather than the dutiable portion. Importers must report the full value of the imported article.
- No claim for entry or duty exemption/reduction under Chapter 99 can be applied if it results in a lower rate of duty or duty-free treatment, but additional duties from other provisions remain applicable.
- CBP may require additional documentation for verification.
Melt and Pour Reporting Requirements
Importers must report the country of melt and pour using the ISO code where the steel was originally processed. For steel derivatives, report the ISO code where the steel was originally melted or “OTH” for other countries. If the steel was melted and poured in the U.S., report “US.”
Exclusions and Drawback
- Importer-specific exclusions remain valid until expiration or full product volume importation.
- All general approved exclusions (GAEs) expire March 11, 2025.
- No drawback is available for duties imposed.
Quota Regulations
All Section 232 tariff rate and absolute quotas expire on March 11, 2025. Entries not achieving quota status by 4:30 p.m. local port time on March 11, 2025, must be refiled as non-quota entries on March 12, 2025.
Foreign Trade Zones (FTZs)
- Any steel or derivative article admitted to a U.S. FTZ on or after March 12, 2025, must be granted “privileged foreign status” and will be subject to duties upon entry for consumption.
- For goods admitted before March 12, 2025, under privileged foreign status, the following HTS codes apply:
- 9903.81.88: Iron or steel products (including those classified under GAEs).
- 9903.81.93: Iron or steel derivative products, except as noted below.
- 9903.81.91: Iron or steel derivative products classified outside of Chapter 73.
- 9903.81.92: Iron or steel derivative products with a U.S. melt and pour origin.
Updated CBP Guidance on Import Duties on Imports of Steel and Steel Derivative Products
Access Section 232 Chapter 99 HTSUS classification lists, and chart
Aluminum and Derivatives
Applicable duty to various classifications of aluminum and derivative aluminum articles under the Harmonized Tariff Schedule of the United States (HTSUS) is as follows:
9903.85.02:
Aluminum products excluding derivative articles listed in subdivision (g).
- 9903.85.04: Derivative aluminum products listed in subdivision (i) (existing aluminum derivative articles subject to Section 232).
- 9903.85.07: Derivative aluminum products listed in subdivision (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232).
- 9903.85.08: Derivative aluminum products listed in subdivision (k) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232). Import duty is based on aluminum content value.
- 9903.85.09: Derivative aluminum articles listed in subdivisions (j) or (k) where the aluminum was processed in another country but originally smelted and cast in the U.S.
Duties Based on Aluminum Content
For aluminum derivative articles outside of Chapter 76, duties are based on the value of the aluminum content:
- If the aluminum content value is unknown or the same as the entered value, report the duty on the full value under HTS 9903.85.08.
- If the aluminum content is a fraction of the entered value, report the non-aluminum and aluminum content separately.
Aluminum Content Reporting
If the value of the aluminum content is the same as the entered value or is unknown, duty must be reported under 9903.85.08 based on the entire entered value, and on only one entry summary line.
In the case where the value of the aluminum content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-aluminum content, the second line will represent the aluminum content. Each line should be reported in accordance with the below instructions.
Non-Aluminum content, first line:
- Ch. 1-97 HTS, this same HTS must be reported on both lines.
- Country of origin, same must be reported on both lines.
- Total entered value of the article less the value of aluminum content.
- Report the total quantity of the imported goods.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Aluminum content, second line:
- Same Ch. 1-97 HTS reported on the first line.
- Same country of origin reported on the first line.
- Report 0 for quantity for the Ch. 1-97 HTS.
- Report the value of the aluminum content.
- Report the Section 232 duties based on the value of aluminum content with HTS 9903.85.08.
- Report a second quantity (of the aluminum content) in kilograms with the HTS 9903.85.08.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties
Duties on Aluminum from Russia
A 200% duty applies to aluminum products and derivatives originating from Russia, smelted in Russia, or cast in Russia. Importers should report:
- 9903.85.67 for aluminum products.
- 9903.85.68 for derivative aluminum products.
Detailed Reporting for Goods Under Chapter 98 for Aluminum
- Goods entered under Chapter 98 provisions will still be subject to the additional duties prescribed for aluminum products.
- Duties under subheading 9802.00.60 must be based on the full value of the imported aluminum product. Importers must report the full value of aluminum goods.
- No claims for duty exemption or reduction under Chapter 99 can be made if it results in a lower duty rate.
- CBP may request supporting documentation for verification purposes.
Smelt and Cast Reporting Requirements
Importers must report the country of smelt (primary and secondary) and the country of the most recent cast using the ISO code. If aluminum is manufactured from recycled materials, the secondary country of smelt should match the country of origin.
Exclusions and Drawback
- Importer-specific exclusions remain valid until expiration or full product volume importation.
- All general approved exclusions (GAEs) expire March 11, 2025.
- No drawback is available for duties imposed.
Quota Regulations
All Section 232 tariff rate and absolute quotas expire on March 11, 2025. Entries not achieving quota status by 4:30 p.m. local port time on March 11, 2025, must be refiled as non-quota entries on March 12, 2025.
Foreign Trade Zones (FTZs)
Aluminum articles admitted to U.S. FTZs on or after March 12, 2025, must be granted “privileged foreign status” and will be subject to applicable duties upon entry for consumption.
Updated CBP Guidance on Import Duties on Imports of Aluminum and Aluminum Derivative Products
Access Section 232 Chapter 99 HTSUS classification lists, and chart
Strategies for Businesses
1. Compliance Adjustments
- Verify correct Harmonized Tariff Schedule (HTS) classification to confirm tariff applicability.
- Explore duty drawback and exemption programs where eligible.
2. Supply Chain Diversification
- Identify alternative suppliers from non-tariffed markets.
- Consider domestic production options to reduce dependency on U.S. exports.
3. Trade Agreement Opportunities
- Assess whether USMCA (formerly NAFTA) provides relief or exemptions.
- Explore alternative free trade agreements (FTAs) for tariff reductions.
4. Cost Mitigation Strategies
- Renegotiate supplier contracts to offset cost increases.
- Evaluate price adjustments or cost-sharing strategies with customers.
How GHY Can Help
The re-imposition of tariffs on Canadian steel and aluminum underscores the volatility of international trade. Businesses must remain agile, leverage expert guidance, and proactively explore solutions to navigate this evolving landscape. GHY stand ready to assist in navigating these turbulent waters, ensuring that Canadian businesses can continue to operate efficiently despite these new barriers.
For tailored customs solutions and strategic guidance, reach out to our team today.
Please contact your Client Care Manager or our Global Trade Services Team gts@ghy.com, or call +1 (800) 667-0771.
Subscribe!
