On February 14, 2025, President Trump revealed two pre-published executive orders containing additional details being made to his February 10, 2025, proclamations that reinstated a 25% tariff on steel imports and an increase of aluminum tariffs from 10% to 25%. These orders now include annexes that describe the Harmonized Tariff Schedule of the United States (HTSUS) codes of additional derivative steel and aluminum articles that will be subject to Section 232 duties.
These annexes are designed to be subject to the proclamations announced last week by President Trump. The updated proclamations with the newly announced annexes are scheduled to be published in the Federal Register on February 18, 2025.
The revised pre-published executive orders are separate as to steel and aluminum articles and each executive order only reveals a new Annex I, which lists HTSUS codes covering steel and aluminum derivatives respectively.
The Annex I listed in each pre-published executive orders disclose that any imports of derivative aluminum articles identified within 123 listed HTSUS codes, and imports of derivative steel articles identified within 135 listed HTSUS codes, shall be subject to the Section 232 duties.
It is important to note that derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States, and derivative steel articles processed in another country from steel articles that were melted and poured in the United States, will not be subject to these duties. Additionally, the annexes state that for any derivative aluminum and steel articles identified within the listed HTSUS codes, or any derivative aluminum or steel articles mentioned in a future Federal Register notice that is not in Chapter 73 or 76 of the HTSUS, the additional duties shall only apply to the aluminum or steel content of the derivative article.
To reiterate, tariffs on derivative articles won’t take effect until notification from the Commerce Department that “adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.” Meanwhile all other products subject to the executive orders will be subject to the tariffs on March 12, 2025.
We will continue to monitor this matter and provide substantive updates as they become available.
Should you have any questions concerning these developments, please contact one of the trade professionals listed here.