What’s New?
- The U.S. Department of Commerce, through the Bureau of Industry and Security (BIS), announced the addition of 407 new HTS codes to the list of “derivative” steel and aluminum items subject to Section 232 tariffs.
- These newly included items now face a 50% duty rate on their steel or aluminum content.
Effective Date and Scope
The tariffs apply to goods entered for consumption or withdrawn from warehouse starting at 12:01 a.m. Eastern Time on Aug. 18, 2025. There is no exemption for goods in transit.
These Section 232 duties are in addition to any other applicable tariffs or trade remedies.
Actions Recommended if Your Product Falls Under an HTS Affected by the Changes to Section 232
The additional duty on derivatives will only apply to the declared value of the steel or aluminum content of the derivative product; however, if the steel or aluminum value is unknown or unreported, then tariffs are due on the full entered value of the affected good.
Changes to commercial invoice:
- Please ensure your commercial invoices provide a breakdown for the value and the kilograms of the steel or aluminum portion of the goods.
- Importers must be able to provide supporting documentation for any claims made which may include: mill certificates, bill of materials, purchase orders, technical information, production processes, certificate of origin, etc.
- If any items that fall under the affected HTS codes do not contain steel or aluminum, please include a statement on the commercial invoice indicating that fact. For example, if you import 100% plastic wheels under the affected tariff 8479.90.9596, your commercial invoice should specifically state that the wheels are 100% plastic and do not contain aluminum.
- Report the melt and pour country for steel content on the commercial invoice.
- Report the country of primary smelt, the country of secondary smelt and the country of cast on the commercial invoice for aluminum content. If country of smelt and cast is unknown, the goods are subject to a 200% tariff.
Changes to bill of material:
- Krieger Worldwide recommends that products that fall under Section 232 have full traceability in terms of steel and aluminum content by providing the actual percentage amount of the bill of material(s).
Further Guidance
- Please see the Aug. 19, 2025, Federal Register for full details on the inclusion of the new HTS codes.
- Please see the original Federal Register notices here: steel and aluminum. The Annex I of each Federal Register lists previously announced affected HTS codes of affected derivative products—this list will continue to be expanded in the future.
Examples of Included Products
The newly added categories span a wide array of industrial, heavy‑equipment, consumer and seemingly unrelated items, including:
- Packaging or components for items such as dairy products, petroleum oils, paint, toiletries, etc.
- Wind turbines and components
- Mobile cranes, bulldozers, heavy equipment
- Furniture
- Compressors and pumps
- Engines, hydraulic motors, loaders, locomotives
Proactively Monitor Your Bonds
If you have products that are newly subject to the Section 232 provisions, please take this time to monitor your bond. Krieger strongly encourages importers to take a proactive approach and not wait for CBP or their surety to initiate contact about potential bond insufficiency. The primary bond required is the basic importation and entry bond, typically set at 10% of the importer’s previous duties, taxes and fees over a rolling 12-month period. To ensure compliance, importers should refer to the most recent guidance from CBP in “A Guide for the Public: How CBP Sets Bond Amounts” (February 2024). CBP advises all importers to review this document, as there are no planned adjustments to the bond calculation formula.
It is crucial for importers to anticipate future needs by anticipating evolving tariffs and reviewing their import volumes over the past 12 months, as well as projecting and anticipating how much business they will do in the next 12 months. If an importer’s products may be subject to new tariffs, importers should engage with their surety to assess potential impacts. Key considerations include determining the premium insurance costs and any collateral requirements, such as a cash deposit or letter of credit, which can impact an importer’s financial leverage. Since CBP does not control the underwriting process, importers must work directly with Krieger and their sureties to ensure they are adequately prepared.
Krieger’s team cannot comment on unreleased tariffs that are not currently in effect but strongly encourages importers to plan ahead by considering both past trends and future projections. The 15-day compliance window for bond adjustments can pose processing challenges, so importers should take proactive measures to secure a higher bond in advance if necessary. Please reach out to the Krieger to mitigate risk and to avoid bond stacking, which is a situation in which multiple bonds are secured for a single importer, which can affect financial solvency.
If you need help reviewing entries or obtaining a freight quotation, our Krieger’s team is here to support you. For a detailed FAQ, tariff impact analysis or to optimize your freight operations, contact cst@nkinc.com.
