Steel and Aluminum: The Gifts That Keep on Giving

Feb. 4, 2025
By: Hannah B. Kreinik

The Department of Commerce published two notices extending the annex lists for both presidential proclamations posted a few weeks ago (see our prior articles on the proclamations here and here). The original annex lists published a few days after the presidential proclamations hinted that more derivative products may follow, and so they have (see our original articles on the annex lists here).

This latest publication confirms more derivative products will be subject to the Section 232 expansion from mid-February. Specifically, the steel annex list now includes articles in Chapter 72 and 83, including, but not limited to, flat-rolled steel articles, certain bars and rods, certain ingots, some stainless steel articles, and drawing pins and staples under heading 8305. The notice also includes Note 16(n), mainly covering articles in Chapters 84, 85, and 94, which provides that the additional duties plus the regular tariff rate for the covered merchandise will not be effective until public notification by the Secertary of Commerce. For the complete list of new additions, please click here.

On the aluminum side, the latest annex list includes new additions from Chapter 76 like unwrought aluminum, bars and profiles, wire, sheets, foil, tubes, and pipes. Note 19 also includes a similar provision under (k) for the aluminum derivative articles subject to the proclamation that will incur the regular tariff rate plus the additional 25% from the proclamation. Like steel, Note 19(k) will not take effect until public notification by the Secretary of Commerce. The derivative products covered under Note 19(k) include a range of goods from Chapters 66, 83, 84, 85, 87, 88, 90, 94, 95, and 96. For a full annex list, please see here.

Importers should be on alert, as it is likely that this sector will continue to receive attention from the current administration. Importers should prepare their steel and aluminum supply chains to face more trade actions either in the form of tariffs, antidumping and countervailing, trade remedies, litigation, or other yet unknown means. The attorneys at Barnes, Richardson & Colburn are here to keep you updated on the latest news for the metal sector and much, much more.