Section 232- Steel and Aluminum Tariffs: A Comprehensive Overview

In recent years, the United States has implemented a series of tariffs on steel and aluminum imports to safeguard domestic industries and address issues of trade imbalances. These tariffs, originally set under Proclamation 10896 (steel) and Proclamation 10895 (aluminum), have been enforced with a particular focus on national security and economic considerations. Continue reading for a comprehensive overview of the steel and aluminum tariffs, the requirements for reporting, the tariff numbers, descriptions, and duty rates, as well as the potential impact of these tariffs on derivative goods.

Background on the Tariffs

The imposition of steel and aluminum tariffs was first formalized by President Donald Trump in 2018, citing Section 232 of the Trade Expansion Act of 1962. This section allows the President to impose tariffs on imports of certain goods if it is determined that these imports threaten national security. In response to concerns about the U.S. steel and aluminum industries’ ability to supply essential materials for national defense and critical infrastructure, Proclamations 10895 and 10896 were issued, establishing tariffs on aluminum and steel imports respectively.

Since their implementation, these tariffs have been subject to adjustments and updates, including revisions communicated through the Federal Register and other official channels like the Customs and Border Protection’s (CBP) CSMS messages (Customs and Trade Automated Interface Requirements).

• Proclamation 10895 addresses tariffs on aluminum, outlining the implementation of duties on aluminum imports.
• Proclamation 10896 focuses on steel, detailing the application of tariffs on imported steel products.

For full details and official documentation on these tariffs, the following Federal Register links can be consulted:

• Federal Register: Implementation of Duties on Steel
• Federal Register: Implementation of Duties on Aluminum

What Are the Steel and Aluminum Tariffs?
The tariffs imposed on steel and aluminum imports are essentially duties applied to the value of goods entering the U.S. from foreign countries. These tariffs are aimed at reducing the volume of imported materials and providing a competitive advantage to domestic manufacturers.

Steel Tariffs: Under Proclamation 10896, the U.S. imposed a 25% tariff on most steel products. The steel tariffs apply to a wide range of steel products, including:

• Carbon steel
• Stainless steel
• Alloy steel
• Bars, rods, and profiles of steel
• Steel sheets and plates

Aluminum Tariffs: Similarly, Proclamation 10895 established a 10% tariff on aluminum products imported into the U.S. The aluminum tariffs apply to various forms of aluminum, including:

• Aluminum plates
• Sheets
• Foil
• Aluminum scrap
• Extrusions and other aluminum derivatives

Tariff Numbers, Descriptions, and Duty Rates
Both steel and aluminum tariffs are organized by Harmonized Tariff Schedule (HTS) codes. The additional steel and aluminum duty rates are applied based on these codes. The HTS codes for steel and aluminum are in addition to the product’s HTS number and duty rate and any other applicable duties, for example, China duties or Antidumping and Countervailing duties.
Based on the Section 232 Tariff Quick-View Chart (March 12, 2025), here is a detailed review of the tariff information: Section 232 chart Final.pdf

Steel Articles

• HTS Code: 99038187
  • Description: Applies to all steel products from any country.
  • Duty Rate: 25% tariff
  • Proclamation Number: 10896
  • Effective Date: March 12, 2025
• HTS Codes: 99038189, 99038190, 99038191
  • Description: Applies to derivative steel articles from any country.
    • If the good has a mixed composition, such as 60% plastic and 40% steel, this applies to goods with a 25% duty based on the value of the steel content.
  • Duty Rate: 25%
  • Proclamation Number: 10896
  • Effective Date: March 12, 2025
• HTS Code: 99038192
  • Description: Steel products processed from steel articles melted and poured in the U.S.
  • Duty Rate: Zero
  • Proclamation Number: 10896
  • Effective Date: March 12, 2025

Aluminum Articles

• HTS Code: 99038502
  • Description: Applies to all aluminum products from any country.
  • Duty Rate: 25%
  • Proclamation Number: 10895
  • Effective Date: March 12, 2025
• HTS Codes: 99038504, 99038507, 99038508
  • Description: Applies to derivative aluminum articles.
    • If the good has a mixed composition, such as 60% plastic and 40% aluminum, this applies to goods with a 25% duty based on the value of the aluminum content.
  • Duty Rate: 25%
  • Proclamation Number: 10895
  • Effective Date: March 12, 2025
• HTS Code: 99038509
  • Description: Aluminum products processed from aluminum articles smelted and cast in the U.S.
  • Duty Rate: Zero
  • Proclamation Number: 10895
  • Effective Date: March 12, 2025
• Russia-Specific Tariffs
  For aluminum and derivative aluminum products from Russia:
  • HTS Code for Aluminum and Derivatives: 9903.85.67, 9903.85.68
  • Duty Rate: 200% (for aluminum and derivatives)
  • Effective Date: April 10, 2024
  • Proclamation Number: 10895

These tariffs reflect the U.S. government’s policy on national security and economic factors influencing the steel and aluminum sectors.
There are additional aluminum and steel tariffs for Foreign Trade Zones.
The exact HTS codes and duty rates can vary, and businesses importing steel and aluminum should ensure they are using the correct codes when filing customs documentation.

Reporting Requirements for Steel and Aluminum Tariffs
The reporting requirements for steel and aluminum imports are governed by Customs and Border Protection (CBP) and involve several essential processes. Importers must ensure that they are compliant with the following:
Filing with CBP: When importing steel or aluminum products, businesses must file an entry with CBP and declare the correct HTS code, along with the corresponding duty rate. Failure to do so can result in penalties, including fines and seizure of goods.

Melt and Pour/Smelt and Cast Origin Declarations: Importers must report the country where the steel was melted and poured and the primary and secondary countries where the aluminum was smelted and the most recent country of cast
Weight and Content Reporting: For derivative products, importers are required to declare the weight of the steel/aluminum content in kilograms (kg) and separately report steel/aluminum and non-steel/aluminum content values, where applicable.
Documentation and Compliance Monitoring: U.S. Customs and Border Protection (CBP) will scrutinize imports to prevent missclassifications; Importers must ensure proper documentation, including mill analysis or mill test certificates, where required, including documentation from the manufacturer for derivative products; “any importer… shall provide any information that may be required, and in such form, as is deemed necessary by CBP in order to permit the administration of these headings.”
Country of Origin: Importers must provide the country of origin for the steel or aluminum goods.
Import Duties: Once the tariff rate is determined, the importer is required to pay the appropriate duties, which are based on the value of the goods being imported. For example, a 25% duty on $100,000 worth of steel means the importer must pay $25,000 in steel duties, plus the other duties that are involved with that product.
Quotas and Exclusions: All general exclusions have expired as of March 11, 2025. Importer-specific product exclusions for Section 232 duties that are active in the “Automated Commercial Environment (ACE) shall remain effective until their expiration date or until excluded product volume is imported, whichever occurs first.” 

The steel and aluminum tariffs, while intended to protect national security and revitalize domestic industries, have far-reaching consequences for both producers and consumers. Importers must navigate the complex landscape of HTS codes, Section 232 requirements, and duty rates, while also considering how these tariffs affect the pricing of derivative goods. Businesses must stay up to date with updates issued by the Federal Register, as well as consult with customs experts to ensure compliance and mitigate financial impact.

With careful navigation of these regulations and strategic planning, businesses can adapt to the realities of these tariffs and maintain their competitiveness in a changing global market.