Guidance for Section 232 Tariffs on aluminum and steel downstream products

U.S. Department of Commerce © U.S. Department of Commerce

Last week, the U.S. Department of Commerce (Commerce) issued the required certification indicating that the appropriate systems are in place to account for steel and aluminum in derivative products. As a result, the 25% Sec. 232 tariffs have now expanded to cover certain downstream products of both aluminum and steel.

A few important notes:

• The revised Harmonized Tariff System codes published last week indicate only that importers will have to report the steel and aluminum content of derivative products in kilograms, but we are still waiting for additional details.
• There is no "on the water" exclusion or further transition period for the derivative products - the steel and aluminum proclamations state that the 25% duty will be imposed on "goods entered for consumption, or withdrawn from warehouse for consumption, on or after the Commerce certification date."