President Trump’s June 3 proclamation increased aluminum and steel tariffs from 25% to 50 %, effective 12:01 a.m. ET on June 4,and included that the non-aluminum, non-steel content of all aluminum and steel articles and derivative articles are subject to tariffs pursuant to Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits), as amended, and any other applicable tariffs.
The additional ad valorem duties described in clause 1 and clause 7 of this proclamation shall apply only to the steel content of articles in Chapter 73 of the HTSUS and only to the aluminum content of articles in Chapter 76 of the HTSUS. Previously chapter 73 and 76 paid on the entire value of the derivative.
The NCBFAA Customs Committee and Counsel of Sandler, Travis & Rosenberg, P.A., want to make our customs broker members aware of HTS numbers that have been removed from the original Customs and Border Protection (CBP) CSMS from June 3 announcing the application of tariffs for imports of aluminum and steel and their derivative products.
The aluminum and steel HTS numbers which have now been deleted from the original CSMS include:
Aluminum
8418.10.00
8418.40.00
8418.30.00
8422.11.00
8450.11.00
8450.20.00
8451.21.00
8451.29.00
8516.60.40
Steel
8418.10.00
8418.40.00
8418.30.00
8422.11.00
8450.11.00
8450.20.00
8451.21.00
8451.29.00
8516.60.40
9403.99.9020
U.S. customs brokers need to verify that duties have not been paid inadvertently against these HTS numbers.
CBP on June 9 provided the trade with updated HTS lists for aluminum and steel.
However, those deleted aluminum and steel HTS numbers have been included in the Commerce Department’s Bureau of Industry and Security (BIS) Federal Register notice of June 12 which stated that household appliances with aluminum and steel content will be subject to Section 232 50% tariffs, effective 12:01 a.m. ET on June 23.
Per CSMS # 65236645 and CSMS #65236374, non-metal content reported on a split derivative line is subject to reciprocal tariffs as of June 4, 2025. The aluminum and steel content subject to Section 232 duties per the instruction, meanwhile, remain not subject to Reciprocal tariffs under HTS 9903.01.33.
Per CSMS # 65236574 – UPDATED GUIDANCE – Proclamation “Adjusting Imports of Aluminum and Steel in the United States,” Amending Executive Order 14289, “Addressing Certain Tariffs on Imported Articles,” the EO 14289, as amended, applies retroactively to entries of merchandise subject to the five applicable tariff measures and entered for consumption or withdrawn from warehouse for consumption on or after March 4, 2025. However, the modified tariff stacking outlined in this message applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on June 4, 2025.
CBP Guidance for Section 232 Aluminum Import Instructions to Report Unknown for Country of Smelt and Cast
Customs and Border Protection (CBP) has provided the trade with the following updated guidance on how to report the country of smelt and cast on derivative aluminum imports when the product is subject to Section 232 aluminum measures, but the importer does not know the country of smelt and cast.
Effective June 28, 2025, for imports of derivative aluminum subject to Section 232 measures, if importers do not know the country of smelt and/or cast then the importers should report “unknown” in lieu of the International Organization for Standardization (ISO) code for the unknown smelt and cast country. When reporting “unknown”, importers will be required to report HTS 9903.85.67 or 9903.85.68, as applicable, and will be assessed the 200 percent Section 232 duties on imports of aluminum from Russia.
