On October 7, 2025, BIS posted a second tranche of requests made by the public for inclusion on the list of derivative products subject to Section 232 tariffs on steel and aluminum derivative products. BIS received 95 inclusion requests in the second submission period that opened on September 15 and closed on September 29. The release of these requests commences a two-week comment period for potential inclusions. The public may make comments on the inclusion requests until October 21, 2025. Comments should be made via the federal eRulemaking portal at www.regulations.gov on  Docket ID no. BIS-2025-0023. As background, on June 3, 2025, President Donald Trump issued proclamation “Adjusting Imports of Aluminum and Steel Into the United States,” that increased the United States’ Section 232 tariffs on steel and aluminum derivative product imports from 25% to 50%. The UK remained at the 25% rate.  See Thompson Hine Update of June 5, 2025.  On August 18, 2025, the Bureau of Industry and Security (BIS) significantly expanded the scope of the steel and aluminum derivative products by adding 407 HTS codes after the first round of inclusion requests began in May, bringing a wide array of finished goods within Section 232 coverage. The agency received 467 requested subheadings to the tariffs in this round. See Thompson Hine Update of August 18, 2025

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Maryam Mahboob Maryam Mahboob

Maryam is an associate in the firm’s International Trade practice group. She focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues and compliance with U.S. sanctions and export control licensing requirements.