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CSMS # 65936570 - GUIDANCE: Section 232 Additional Steel Derivative Tariff Inclusion Products

The purpose of this message is to provide guidance on adding additional steel derivative products to Annex I of the Harmonized Tariff Schedule of the United States (HTSUS) under Proclamation 10896.

BACKGROUND

On February 10, 2025, the President issued Proclamation 10896, “Adjusting Imports of Steel into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  This proclamation imposes a 25 percent ad valorem tariff on certain imports of steel articles and derivative steel articles from all countries, effective June 23, 2025. See 90 FR 11249 (March 5, 2025).

In Proclamation 10896, the President authorized and directed the Secretary of Commerce to publish modifications to the HTSUS to reflect the amendments and effective dates in the proclamation.

Effective August 18, 2025, in accordance with “Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process” the Commerce Department will be adding additional steel derivative products to Annex I of the HTSUS to be subject to Section 232 duties.   Further, Annex II makes technical corrections to the Harmonized Tariff Schedule of the United States.

ENTRY FILING INSTRUCTIONS

This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) on certain steel derivative imports, effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on August 18, 2025.  The following steel derivative products added to subdivisions (m/n/t/u) of U.S. Note 16 of the Harmonized Tariff Schedule of the United States (HTSUS) are subject to Section 232 duties. 

Review the attached steel HTS list to see the additional products (identified in bold) added to the below Chapter 99 HTSUS:

Report the Section 232 steel derivative duties applicable to goods classified in the eight-digit subheadings and the 10-digit statistical reporting number listed in the attached steel HTS list (hereinafter the “newly-added goods”) under the following Chapter 99 HTSUS numbers:

• 9903.81.90 (all countries except the United Kingdom): Derivative iron or steel products listed in subdivision (m): the import duty is on the value of the steel content.
  • 50 percent ad valorem duty on the value of the steel content.

• 9903.81.91 (all countries except the United Kingdom): Derivative iron or steel products listed in subdivision (n) (certain steel derivative articles not classified in Chapter 73 subject to Section 232): the import duty is on the value of the steel content.
  • 9903.81.91 also applies to newly-added goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before August 18, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after August 18, 2025.
  • 50 percent ad valorem duty on the value of the steel content.

• 9903.81.97 (UK only): Derivative iron or steel products listed in subdivision (t): the import duty is on the value of the steel content.
  • 25 percent ad valorem duty on the value of the steel content.

• 9903.81.98 (UK only): Derivative iron or steel products from United Kingdom listed in subdivision (u) (certain steel derivative articles not classified in Chapter 73 subject to Section 232): the import duty is on the value of the steel content.
  • 9903.81.98 also applies to newly-added goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before August 18, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after August 18, 2025.
  • 25 percent ad valorem duty on the value of the steel content. 

• 9903.81.92 (all countries, including the UK): Derivative steel or iron products listed in subdivisions including (n) or (u) where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States.
  • 9903.81.92 also applies to newly-added goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before August 18, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after August 18, 2025.
  • 0 percent ad valorem duty.

See CSMS # 65236374 for steel content reporting instructions.

Application of Reciprocal Tariffs under EO 14257

The non-steel content of an article reported on a separate line per the instructions identified in CSMS 65236374, is subject to Reciprocal tariffs under HTS 9903.01.25.  The steel content subject to Section 232 duties is not subject to Reciprocal tariffs under HTS 9903.01.33.

Drawback

No drawback shall be available with respect to the duties imposed pursuant to Proclamation 10896.

Consult the Section 232 Tariffs on Steel and Aluminum Frequently Asked Questions (FAQs) for additional guidance, including on reporting country of melt and pour, determining the value of steel content and reporting requirements on goods subject to both steel and aluminum duties.

For reference, a summary of Section 232 Chapter 99 HTSUS classifications is attached.

For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.

If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.

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