U.S. Spotlight Newsletter | Aluminum Section 232 When Country is Unknown; New Products Subject to Steel Derivative Section 232 Tariffs

Effective June 28, 2025, for entries of derivative aluminum products subject to the Section 232 measures, if an importer does not know the country of smelt and/or cast then the importer must report “unknown”. 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 applicable on imports of aluminum from Russia.

The reason for the above is that subject products that contain Russian sourced aluminum are subject to a higher Section 232 tariff rate than that of products that contain non-Russian aluminum. If the source of the aluminum is unknown by the importer, then the potential exists that material is Russian sourced.   

Importers should strive to confirm and provide the actual country of cast/smelt of the aluminum within their subject product so (as long as not Russia) the product will be assessed the standard 50% Section 232 tariff instead of the higher Russian rate.

Further details may be found at: CSMS # 65340246 – GUIDANCE: Section 232 Aluminum Import Instructions for Reporting Unknown for the Country of Smelt and Cast

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on June 23, 2025, the following steel derivative products classified in Chapters 84, 85 and 94 of the Harmonized Tariff Schedule of the United States (HTSUS) are subject to Section 232 duties:

(1) combined refrigerator-freezers under HTSUS subheading 8418.10.00;
(2) small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
(3) washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
(4) dishwashers under HTSUS subheading 8422.11.00;
(5) chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
(6) cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
(7) food waste disposals under HTSUS subheading 8509.80.20; and
(8) welded wire rack under statistical reporting number 9403.99.9020.
(Note that HTSUS 9403.99.9020 is also subject to Section 232 measures on aluminum derivatives articles per Proclamation 10895)

On products entered under the above HTS classifications, the value of the steel content within the product will be subject to Section 232 tariffs as follows-
•    UK origin products subject to 25% tariff rate via application of HTSUS 9903.81.98. 
•    Products of any origin other than UK subject to 50% tariff rate via application of HTSUS 9903.81.91.
•    If the steel within the product was melted and poured in the U.S. then product is exempt from the tariffs via application of 9903.82.92.

Further details may be found at:
CSMS # 65405824 – GUIDANCE: Section 232 Additional Steel Derivative Products