Overview
On August 19, 2025, the Department of Commerce's (DOC) Bureau of Industry of Security (BIS), published a Federal Register notice that added 407 HTSUS codes to the list of steel and aluminum derivative products subject to a 50% tariff under Section 232 of the Trade Expansion Act of 1962 (Section 232). These additions follow from a directive issued by President Trump to DOC in February, for the agency to establish a process for including additional derivative aluminum and steel articles within the scope of current Section 232 steel and aluminum actions.
The process was designed to enable companies that compete with imported merchandise containing steel and aluminum components to expand the coverage of the previously issued Section 232 duties to cover those imports. The products added today are the result of the first round of requests, which were filed in May 2025. BIS appears to have approved all or virtually all of these requests, unless the product was already subject to certain trade actions or investigations such as a pending Section 232 inquiry.
The products added are described at the 8-digit or 10-digit HTSUS level, and those specific products fall into the following categories of products (among others):
- paints and varnishes
- gases such as propane, oxygen, and propylene
- certain furniture
- trailers
- motorcycles
- parts of railway or tramway locomotives
- tractors, bulldozers, fork-lifts, cranes, levelers, and other similar vehicles and parts
- electrical transformers
- ball bearings
- molds for rubber or plastics
- air conditioners, refrigerators, and other appliances
- boiler parts
- engines, motors, gear boxes, clutches, pumps, and other mechanical parts
- bearings
- wind turbine blades,
- certain types of tableware
- knives, tools, and dies
- aluminum containers
- trailers
- pesticides, insecticides, and other chemicals
- hinges as other base metal mountings
- beauty and hair products
- lubricants, polishes, glues, and adhesives
- certain milk and other food products
A number of the codes relate to products which themselves contain no steel or aluminum content, but which are packaged in steel and aluminum, such as chemicals, paint, certain dairy products, and gases. A full list of added HTS codes is listed in Annex I of the Federal Register notice. Importers of products falling into these categories should confirm immediately whether their products are or could be subject to additional duties.
Starting immediately, a 50% tariff will apply to the steel and aluminum content of these products. The non-steel and non-aluminum content will remain subject to the reciprocal and other applicable tariffs. Products on this list that were manufactured in another country from steel that was melted and poured in the United States or from aluminum that was smelted and cast in the United States are exempted from the Section 232 tariffs.
The next window for requests to add products to the steel and aluminum derivative product list will open on September 1, 2025 and last for two weeks. There will be a 14-day comment period, and BIS is supposed to issue its decision within 60 days of receiving the request.
For more information on these Section 232 tariffs, assistance with submitting a comment or request in the steel/aluminum derivative inclusions process, or questions on how any potential trade action may impact your business, please contact a member of Steptoe's Trade Policy or Trade Remedies practices.
