Industry News
Commerce Adds 407 (!) HTS Codes to 232 Derivative Annexes Starting Monday
TweetAug. 15, 2025
By:
Hannah B. Kreinik
In a dramatic addition to the scope of steel and aluminum 232 derivative duties, the Commerce Department released a
public inspection notice adding over 400 new HTS codes to the Section 232 derivatives list. The new additions will be subject to duties effective 12:01 am (ET) on Monday, August 18th. The latest additions are from the Commerce Department’s first round using the Section 232 inclusion process (details on the process are available here).
The range of newly included products is very broad, including many articles not traditionally considered to be “steel or aluminum derivatives.” New steel derivative inclusions, include but not limited to, anti-freezing preparations (3820.00.00), cold-formed or cold-finished flat-rolled products (7216.91.0010), stranded wire with steel core (7614.10.10), knives (8211), brackets and mountings (8302.10 & 8302.41), parts of generators for aircraft (8503.00.35), parts of railways or tramways (8607), other parts of motor vehicles (8708.99.81), and metal office furniture (9403.10). New aluminum derivative inclusions cover products like aluminum stoppers, caps, and lids (8309.90), parts of engines and motors (8412.90), internal combustion engine generating sets (8502.20), insulated wiring (8544.49), and other kinds of seats (9401.79). Different from the other 232 orders, these additions do not include an exception for goods entered as “privileged foreign status” in an FTZ. However, application of the duties to the value of the steel and aluminum content carries over from previous orders, articles made from U.S. steel or aluminum are exempted, and reciprocals will apply to the remaining value of the goods.
Barnes, Richardson & Colburn attorneys are here to assist your company in determining which, if any, of the Section 232 orders apply to your products.
The range of newly included products is very broad, including many articles not traditionally considered to be “steel or aluminum derivatives.” New steel derivative inclusions, include but not limited to, anti-freezing preparations (3820.00.00), cold-formed or cold-finished flat-rolled products (7216.91.0010), stranded wire with steel core (7614.10.10), knives (8211), brackets and mountings (8302.10 & 8302.41), parts of generators for aircraft (8503.00.35), parts of railways or tramways (8607), other parts of motor vehicles (8708.99.81), and metal office furniture (9403.10). New aluminum derivative inclusions cover products like aluminum stoppers, caps, and lids (8309.90), parts of engines and motors (8412.90), internal combustion engine generating sets (8502.20), insulated wiring (8544.49), and other kinds of seats (9401.79). Different from the other 232 orders, these additions do not include an exception for goods entered as “privileged foreign status” in an FTZ. However, application of the duties to the value of the steel and aluminum content carries over from previous orders, articles made from U.S. steel or aluminum are exempted, and reciprocals will apply to the remaining value of the goods.
Barnes, Richardson & Colburn attorneys are here to assist your company in determining which, if any, of the Section 232 orders apply to your products.
