On August 15, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Federal Register notice adding 407 codes from the Harmonized Tariff Schedule of the United States (HTSUS) to the list of steel and aluminum derivative products. As a result, these products will now be subject to the Section 232 tariff on steel and aluminum—currently set at 50%—under the Trade Expansion Act of 1962. (For additional background, see Update of February 12, 2025 (modifying the Section 232 tariffs), Update of February 14, 2025 (announcing the initial list of steel and aluminum derivative products), and Update of June 5, 2025 (increasing the tariff rate from 25% to 50%.)
Pursuant to Proclamation 10947, issued by President Donald Trump on June 3, 2025, the Section 232 tariff applies only to the value of the steel and aluminum content in a product. Any non-steel or non-aluminum content remains subject to other applicable tariffs.
These 407 newly designated derivative products will become subject to the Section 232 tariff starting August 18, 2025; however, the notice does not include a savings clause, meaning goods already on their final mode of transit will be subject to the tariff upon their entry into the United States if they arrive on or after the effective date.
Section 232 authorizes the president to impose import restrictions when imported goods are determined to be entering the United States in quantities or under circumstances that “threaten to impair” national security. While it is common for importers to associate this Section 232 tariff with goods classified under HTSUS Chapter 73 (“Articles of Iron or Steel”) and Chapter 76 (“Aluminum and Articles Thereof”), the expanded list from BIS targets downstream products that rely on steel or aluminum components. The BIS notice specifies that the Section 232 tariff will now apply to:
- Steel derivative goods under HTSUS Chapters 4, 21, 27, 28, 29, 30, 32, 33, 34, 35, 38, 39, 72, 73, 76, 82, 83, 84, 85, 86, 87, and 94; and
- Aluminum derivative goods under HTSUS Chapters 4, 21, 27, 29, 30, 32, 33, 34, 35, 37, 38, 73, 76, 83, 84, 85, 87, and 94.
This action reflects the “inclusions process” described in both Proclamation 10895 (the Section 232 tariff on aluminum) and Proclamation 10896 (the Section 232 tariff on steel), which directed the Department of Commerce to create a procedure for the public to request specific HTSUS codes be added to the scope of the Section 232 tariffs.
To that end, BIS published an interim final rule on May 2, 2025, establishing three annual two-week submission windows—in May, September, and January—for filing such requests. New or previously unsuccessful submissions from the initial round can be (re)submitted during the next window, which is open between September 1-15, 2025.