WHAT’S THE LATEST

Effective on August 18 at 12:01 a.m. ET, the U.S. Department of Commerce (Commerce) has added more than 400 additional steel and aluminum derivative products to be subject to Section 232 duties. These products are now subject to the 50% Section 232 tariff.

WHAT'S WE KNOW

  • In its notice, Commerce added 407 additional Harmonized Tariff Schedule of the United States (HTSUS) codes of products that are now within scope of Section 232 Orders on Steel & Aluminum and subject to 50% tariff based on cost of aluminum. 
  • The additional products and HTSUS codes are listed in Annex I of the notice.  
  • The Section 232 tariff is in addition to any other applicable tariffs. 
  • There is no exemption for items in-transit. 
  • The Commerce notice, in Annex II, also makes technical correction to the HTSUS.  

WHAT'S NEXT?

To ensure compliance with the updated requirements, SEKO recommends importers take the following actions: 

  • Ensure full supply chain visibility for aluminum products to accurately declare the country of smelt and/or cast.
  • Provide supporting documentation if requested by CBP. 

Scenario-Based Reporting Guidance: 

  • If the country of smelt and cast is known it should be indicated on entry documents and SEKO will report it at time of entry.  
  • If the smelt and/or cast occurred in the U.S. this should be indicated on entry paperwork and SEKO will apply the appropriate domestic aluminum exclusion.  
  • If the product contains 0% aluminum, SEKO will enter “N/A” for the primary smelt country and list the country of origin as secondary, per CBP FAQs.  
  • If the country of smelt and/or cast is unknown: 
    • SEKO will contact the importer to explain CBP’s new guidance and encourage further inquiry.  
    • If origin still cannot be confirmed, SEKO must declare to Russia, triggering the 200% tariff on the Importer of Record. 

Using HTS classification databases and maintaining up-to-date documentation is essential in today’s evolving trade landscape. Importers exploring strategies to mitigate tariffs should coordinate closely with their Customs Broker to ensure accurate, compliant documentation. 

We recommend using SEKO's Steel & Aluminum Form to communicate cost and other reporting elements associated with steel/aluminum data.  

If you have questions, please reach out to your SEKO representative, or email us at hello@sekologistics.com.