Updated Guidance on Import Duties for Aluminum and Steel Products

March 12, 2025. We would like to inform you of important updates regarding the import duties on aluminum, aluminum derivative products, steel, and steel derivative products, effective March 12, 2025. These changes are based on the recent proclamations issued by the President and certified by the Secretary of Commerce.

Key Updates

• Effective Date: The new import duties will be effective from 12:01 a.m. Eastern Daylight Time on March 12, 2025.
• Duty Rates:
  • A 25 percent duty rate will apply to certain aluminum and steel products and their derivatives.
  • A 0 percent duty rate will apply to derivative aluminum articles processed in another country from aluminum articles smelted and cast in the United States.

Detailed Duty Rates for Aluminum

• 25 percent duty rate:
  • HTSUS 9903.85.02: Aluminum products except derivative articles listed in subdivision (g).
  • HTSUS 9903.85.04: Derivative aluminum products listed in subdivision (i).
  • HTSUS 9903.85.07: Derivative aluminum products listed in subdivision (j).
  • HTSUS 9903.85.08: Derivative aluminum products listed in subdivision (k), based on the value of the aluminum content.
• 0 percent duty rate:
  • HTSUS 9903.85.09: Derivative aluminum articles listed in subdivision (j) or (k), processed in another country from aluminum articles smelted and cast in the United States.

Click here to read the complete Federal Register notice.

Detailed Duty Rates for Steel

• 25 percent duty rate:
  • HTSUS 9903.81.87: Iron or steel products listed in subdivision (j) (except derivative articles).
  • HTSUS 9903.81.88: Iron or steel products admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025.
  • HTSUS 9903.81.89: Derivative iron or steel products listed in subdivision (l) (existing steel derivative articles subject to Section 232).
  • HTSUS 9903.81.90: Derivative iron or steel products listed in subdivision (m) (new steel derivative articles classified in Chapter 73 subject to Section 232).
  • HTSUS 9903.81.91: Derivative iron or steel products listed in subdivision (n) (new steel derivative articles not classified in Chapter 73 subject to Section 232).
  • HTSUS 9903.81.92: Derivative iron or steel products listed in subdivision (m) or (n), processed in another country from steel melted and poured in the United States.
  • HTSUS 9903.81.93: Derivative products of iron or steel admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025.

Click here to read the complete Federal Register notice.

Reporting Instructions for Derivatives

For new aluminum and steel derivatives not classified in their respective chapters, the 25 percent duty is to be reported based on the value of the aluminum or steel content. Detailed instructions are provided for reporting non-aluminum/steel and aluminum/steel content separately:

• If the aluminum/steel content value is unknown or the same as the entered value, report the duty on the full value under the respective HTS code.
• If the aluminum/steel content is a fraction of the entered value, report the non-aluminum/steel and aluminum/steel content separately.

Commercial Invoice Values

Importers must ensure that their commercial invoices clearly indicate the weight in kilograms (kg) and the value of the aluminum or steel content of their products. This information is crucial for accurate duty calculation and compliance with reporting requirements. Best practices include adding detailed information to your commercial invoice and communicating this information to your customs broker.

Duties for Aluminum and Steel from Russia

The 200 percent duties on aluminum and steel products and their derivatives from Russia remain in effect. Importers should continue to report HTS heading 9903.85.67 for aluminum products, 9903.85.68 for aluminum derivative products, and the corresponding HTS headings for steel products.

Smelt and Cast Reporting Requirements

Importers must report the ISO code on aluminum and steel articles and their derivatives for all countries subject to Section 232. Specific instructions are provided for reporting primary and secondary countries of smelt and cast.

Exclusions and Drawback

Importer-specific product exclusions for Section 232 duties that are active in ACE will remain effective until their expiration date or until excluded product volume is imported, whichever occurs first. All general approved exclusions (GAEs) will expire on March 11, 2025, and products will be subject to 25 percent ad valorem duties on March 12, 2025. No drawback will be available with respect to the duties imposed.

Quota

All Section 232 tariff rate and absolute quotas will expire on March 11, 2025. Entries that do not achieve quota status by 4:30 local port time on March 11, 2025, must be refiled as non-quota entries on March 12, 2025.

Foreign Trade Zone (FTZ)

Any aluminum or steel articles and their derivatives subject to the duty imposed by this proclamation and admitted into a U.S. foreign trade zone on or after the Commerce certification date may be admitted only under “privileged foreign status” and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading. We appreciate your attention to these important updates. Should you have any questions or require further assistance, please do not hesitate to reach out to your Buckland representative.