Steel & Aluminum Tariff Increases & Derivative Product Details

As discussed in our previous email, the President issued a detailed proclamation (Executive Order) on February 18th, imposing tariffs on all steel and aluminum products imported from countries outside the United States. These tariffs take effect for goods arriving and clearing U.S. customs on or after March 12th.

This proclamation, including the annex of HTS codes, was officially filed with the Federal Register on February 18th. Please note the following key changes that may affect your business:

Steel and Aluminum Product Tariff Increases and Updates:

All existing exemptions and exclusions for steel and aluminum product tariffs, regardless of the country of origin, have been removed. The tariff rate for aluminum products has increased from 10% to 25%.

Tariffs on derivative products (on the aluminum and steel content only)

Beyond primary steel and aluminum mill products (raw steel and aluminum), the proclamation extends tariffs to a broad range of manufactured goods containing aluminum and steel. The attached annex lists the relevant HTS codes, encompassing 123 derivative aluminum products and 167 derivative steel products. Note that this list may be expanded in the future.

However, for the majority of these derivative products (with 18 exceptions), the new tariff will be applied only to the value of the aluminum and steel content. The remaining value of the product will not be subject to the tariff. The Commerce Department is developing a process for importers to efficiently and effectively declare the aluminum and steel value of the product.

Implementation Timeline:

• Revised tariffs on steel and aluminum products apply to goods arriving and clearing U.S. customs on or after March 12th at 12:01 AM.
  
• Tariffs on derivative products will take effect at a later date, to be announced by the Commerce Department, as the aforementioned valuation mechanism is still under development.

We will continue to monitor developments and keep you updated. Please reply to this email if you have any questions about how these changes affect your filings or require further information related to the filing process