CBP has finally published guidance on how to calculate tariffs on the non-chapter 73 and 76 derivative steel and aluminum articles under the expanded Section 232 tariff. It is important for importers to first verify if the product's HTS classification is on the steel derivative list, the aluminum derivative list, or BOTH lists.
If the Product HTS Classification Is ONLY On The Steel List
The 25% steel tariff will be calculated based on the value of the steel content. The steel content will be reported on the entry summary as a separate line from the non-steel content. The entry summary will end up having two lines for each item subject to the steel tariff: one line for the non-steel content and one line for the steel content. Importers will need to provide on the commercial invoice the following breakdown:
Important warning: Please make sure to check with suppliers to make sure the steel is not melted or poured in Russia. If so, the steel will be subject to a 200% tariff.
If the Product HTS Classification Is ONLY On The Aluminum List
The 25% aluminum tariff will be calculated based on the value of the aluminum content. The aluminum content will be reported on the entry summary as a separate line from the non-aluminum content. The entry summary will end up having two lines for each item subject to the aluminum tariff: one line for the non-aluminum content and one line for the aluminum content. Importers will need to provide on the commercial invoice the following breakdown:
Important warning: Please make sure to check with suppliers to make sure the aluminum is not smelt or cast in Russia. If so, the aluminum will be subject to a 200% tariff.
If the Product HTS Classification Is On Both the Steel and Aluminum Lists
A 25% tariff will be calculated based on the value of the steel content. Another 25% tariff will be calculated based on the aluminum content. The entry summary will end up having three lines in this scenario: one line for the non-steel and non-aluminum content, one line for the steel content, and one line for the aluminum content. Importers will need to provide on the commercial invoice the following breakdown.
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Value of the non-steel and non-aluminum content
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Country of origin
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Quantity
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Value of the steel content
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Weight of the steel content in kilograms (kgs)
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Country of melt and pour of the steel
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If there isn't any steel content, importers may indicate "no steel content" as part of the description of the product
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Value of the aluminum content
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Weight of the aluminum content in kilograms (kgs)
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Country of smelt, secondary country of smelt, or country of most recent cast.
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If there isn't any aluminum content, importers may indicate "no aluminum content" as part of the description of the product.
Tariff Implementation Date
We still do not know when CBP will begin assessing the 25% tariffs on the NON-chapter 73/76 derivative products. We are waiting for an announcement from the Secretary of Commerce. However, given the additional extra information that is required to be reported, I highly recommend importers begin working with their vendors to gather the required information. Vendors will need to figure out a clear way to provide the requested information on commercial invoices. There may be some confusion. Feel free to reach out to our team if you have any questions about the best way to report the required information on the commercial invoice.
Note that if the product IS a chapter 73/76 steel/aluminum derivative product, the updated 25% tariff will be assessed starting March 12, 2025.
