Cargo Systems Messaging Service

CSMS # 65936615 - GUIDANCE: Section 232 Additional Aluminum Derivative Tariff Inclusion Products

The purpose of this message is to provide guidance on adding additional aluminum derivative products to Annex I of the Harmonized Tariff Schedule of the United States (HTSUS) under Proclamation 10895.

BACKGROUND

On February 10, 2025, the President issued Proclamation 10895, adjusting imports of aluminum into the United States (90 FR 9807). This Proclamation instructed the United States International Trade Commission, in consultation with the Secretary of Commerce, the Commissioner of United States Customs and Border Protection (CBP) within the Department of Homeland Security, and other relevant executive agencies, to revise the HTSUS so that it conforms to the amendments and effective dates outlined in the proclamation.

Proclamation 10895 authorized the Secretary of Commerce to publish modifications to the HTSUS to reflect these amendments.

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 aluminum 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Protection (CBP) on certain aluminum derivative imports, effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on August 18, 2025.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 aluminum derivative products added to subdivisions (j/k/r/s) of U.S. Note 19 of the Harmonized Tariff Schedule of the United States (HTSUS) are subject to Section 232 duties. 

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

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

• 9903.85.07 (all countries except the United Kingdom):  Derivative aluminum products listed in subdivisions (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232.
  • 50 percent ad valorem duty on the value of the aluminum content.

• 9903.85.08 (all countries except the United Kingdom):  Derivative aluminum products listed in subdivisions (k) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232): the import duty is based upon the value of the aluminum content.
  • 50 percent ad valorem duty on the value of the aluminum content.

• 9903.85.09:  Derivative aluminum products listed in subdivisions (j), (k), (r), or (s) (new aluminum derivative articles processed in another country from aluminum articles smelted and cast in the United States subject to Section 232): (j)/(r)(k)(s)
  • 0 percent ad valorem duty.

• 9903.85.14 (UK only): Derivative aluminum products listed in subdivisions (r) (new aluminum derivative articles classified in Chapter 76 subject to Section 232).
  
  •     25 percent ad valorem duty on the value of the aluminum content.

• 9903.85.15 (UK only): Derivative aluminum products listed in subdivisions (s) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232): the import duty is based upon the value of the aluminum content.
  
  • 25 percent ad valorem duty on the value of the aluminum content.

See CSMS # 65236645 for aluminum content reporting instructions.

Application of Reciprocal Tariffs under EO 14257

• The non-aluminum content of an article reported on a separate line per the instructions above is subject to Reciprocal tariffs under HTS 9903.01.25. 
• The aluminum content subject to Section 232 duties per the instruction above is not subject to Reciprocal tariffs under HTS 9903.01.33.

Duties for Aluminum from Russia

The 200 percent duty on any aluminum products and derivative aluminum products subject to Section 232 that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, is still in effect.  These duties are to be applied to the entire value of the imported good.  Importers should continue to report HTSUS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products; subject to the 200 percent Russia aluminum duties.

9903.85.68 and 9903.85.70: Derivative aluminum articles that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, when such derivative articles are provided for in the headings or subheadings enumerated in note 19(a)(iii) or notes 19(i), 19(j) or 19(k) as applicable per the date of entry for consumption or withdrawal from warehouse for consumption.

Smelt and Cast Reporting Requirements

To report the primary country of smelt, secondary country of smelt, or country of most recent cast.  Importers must report the International Organization for Standardization (ISO) code on aluminum articles and derivative aluminum articles on all countries subject to section 232.  

Filers must report “Y” for primary country of smelt; and/or secondary country of smelt. Filers may not report “N” for both primary country of smelt and secondary country of smelt.

For the Importer's Additional Declaration Record Type '07' if either the derivative aluminum primary and/or secondary country of smelt or country of cast is unknown, report ‘UN’ (unknown) for the ISO country code. When reporting ‘UN’, the 200 percent Section 232 duties for Russia aluminum will be assessed on the entry summary line.

If the imported aluminum is manufactured only from recycled aluminum, then filers should report “Y” for the secondary country of smelt, and report the country reported as the country of origin of the imported article as the secondary country of smelt code.  Take note that aluminum manufactured only from recycled aluminum is not common.  Importers must be able to provide manufacturing documents, upon request, to substantiate the manufacturing process for the recycled aluminum product.

Country of Origin: If the imported product was smelted and cast in the United States, then the importer will report “US” for the country of smelt and “US” for the country of cast.

Drawback

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

Foreign Trade Zone (FTZ)

Any aluminum articles or derivative aluminum articles, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that are subject to the duty imposed by this Proclamation and that are admitted into a U.S. foreign trade zone on or after the Commerce certification date, in accordance with clause 9, may be admitted only under “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading.

The smelt and cast reporting requirements also apply to goods admitted into a U.S. FTZ and withdrawn from the FTZ for consumption, on or after 12:01 a.m. Eastern Daylight Time on August 18, 2025.

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 list 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.

Related messages: CSMS # 65236645, CSMS # 64348411, CSMS # 64384423