Steel and Aluminum Derivative Annexes

Tweet

Feb. 14, 2025
By: Lawrence M. Friedman

The steel and aluminum orders published February 10, covered here, referred to an Annex identifying the expanded list of "derivative articles" that will be subject to the 25% tariff on steel and aluminum products. 

The orders, together with the Annexes, are now available as pre-publication documents at the Federal Register. The links are:

Aluminum Proclamation with Annex

Steel Proclamation with Annex

The Annexes deserve careful attention as they significantly expand the number of HTSUS items subject to Section 232 duties. For example, the Aluminum Annex adds articles of Heading 8302 (mountings, fittings, brackets, etc.), air conditioning parts in 8415.90, vehicle parts in 8708, sports equipment of 9506, and other items. The Steel Annex adds many items in Chapter 73. Outside of Chapter 73, it adds machinery parts of 8431and agricultural equipment of 8432.

The items listed in each Annex will be subject to additional duties imposed by the original Section 232 duty. Derivative steel articles processed in another country from steel that was melted and poured in the United States will be exempt. For the steel items listed on the Annex that are not classified within Chapter 73, the additional duty applies only to the steel content of that derivative article.

For aluminum derivative products, the rate will increase to 25% from the original 10%. For items not classified in Chapter 76, the additional duty will apply only to the aluminum content. Derivative aluminum items processing in another country from aluminum articles that were smelted and cast in the United States are exempt. This proclamation does not change the treatment of derivative aluminum products containing "any amount of primary aluminum that was smelted in Russia or of derivative aluminum articles that were cast in Russia." Those items remain subject to the 200% duties previously imposed.