Aluminum and Steel Tariffs going into effect on March 12

As previously discussed, the President signed an Executive Order implementing steel and aluminum tariffs for all countries, increasing aluminum tariffs from 10% to 25%, and adding a list of HS codes for steel and aluminum derivative products.

CBP Clarifications (March 7, 2025)

CBP resolved ambiguity in the added HS codes of the steel and aluminum derivatives products. In their clarification, the CBP broke down the list of added derivative products into two categories:

• Chapter 76 and 73: The added HS codes under chapters 76 (aluminum) and 73 (steel) face a 25% tariff on the full value.
• Outside Chapter 76 and 73: The remaining codes on the list, which are not in chapters 76 or 73, will have the tariff applied to their aluminum and steel content only.

Details on the Filing Process

For the aluminum and steel derivative products mentioned above, CBP provided the following guidance:

• If the value of the aluminum and steel content is the same as or unknown, a 25% tariff must be reported on the entire entered value.
  
• If the value of the aluminum and steel content is less than the entered value, the goods will be reported on two lines: the first line for non-Aluminum/Steel content, the second line will represent the aluminum/Steel content.  

Effective Date

• March 12 2025: The 25% tariff applies to the general aluminum products from Chapter 76 (19 codes), and Chapter 73 steel (155 codes).
  
• Date TBD: Tariffs on the rest of the products 104 aluminum and 12 steel codes apply only to their metal content, effective once the Commerce Secretary announces a streamlined process.

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We’ll keep you updated as details evolve. Please reach out with any questions.