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CSMS # 64639013 - GUIDANCE: Section 232 Additional Aluminum Derivative Products

The purpose of this message is to provide guidance on additional aluminum derivative products subject to Section 232 duties added to Annex 1 of Implementation of Duties on Aluminum Pursuant to Proclamation 10895 Adjusting Imports of Aluminum into the United States, 90 FR 11251 (March 5, 2025).     

BACKGROUND

On February 10, 2025, the President issued Proclamation 10895, “Adjusting Imports of Aluminum into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), imposing 25 percent ad valorem tariffs on all imports of derivative aluminum articles from all countries, effective March 12, 2025.  See Adjusting Imports of Aluminum into the United States, 90 FR 9807 (February 10, 2025). 

In Proclamation 10895, the President authorized and directed the Secretary of Commerce to publish modifications to the Harmonized Tariff Schedule of the United States (HTSUS) so that it conforms to the amendments and effective dates in the proclamation.

On March 5, 2025, the Bureau of Industry and Security (BIS), U.S. Department of Commerce, published the necessary modifications to the HTSUS in

Annex 1 of Implementation of Duties on Aluminum Pursuant to Proclamation 10895 Adjusting Imports of Aluminum into the United States, 90 FR 11251 (March 5, 2025).   

On April 4, 2025, BIS published the notice in the Federal Register, Implementation of Duties on Aluminum Derivatives Beer and Empty Aluminum Cans Pursuant to Proclamation 10895 Adjusting Imports of Aluminum into the United States, revising Annex 1 to add aluminum derivative products subject to the 25 percent ad valorem tariffs on imports from all countries effective on or after 12:01 a.m. eastern daylight time on April 4, 2025.

ENTRY FILING INSTRUCTIONS

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 4, 2025, the following Chapter 99 HTSUS classifications apply for goods imported under HTSUS 7612.90.10, 2203.00.0060, and 2203.00.0090:

For HTSUS 7612.90.10:

• 9903.85.07: Derivative aluminum products listed in subdivision (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232).
  25 percent ad valorem duty.

For HTSUS 2203.00.0060 and 2203.00.0090:

• 9903.85.08: Derivative aluminum products listed in subdivision (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.
  25 percent ad valorem duty

See CSMS #64384496 for instructions on how to report the value of the aluminum content.

For HTSUS 2203.00.0060, 2203.00.0090, and 7612.90.10:

• 9903.85.09: Derivative steel articles listed in subdivision (j) or (k) (new derivative aluminum articles), where the derivative aluminum products were processed in another country from aluminum articles that were smelted and cast in the United States.
  0 percent ad valorem duty

Duties for Aluminum from Russia

The 200 percent duties on any 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, are still in effect. These duties are to be applied on the entire value of the imported good. Importers should continue to report HTSUS heading 9903.85.68 for aluminum derivative products subject to the 200 percent Russia aluminum duties.

SMELT AND CAST REPORTING REQUIREMENTS

See CSMS #64384496 for instructions on how to report the smelt and cast fields.

Where the product does not contain aluminum content, but has a HTSUS classification that would be subject to Section 232 measures on derivative steel or aluminum articles if it contained aluminum, ACE will still require the aluminum smelt and cast country to be reported.

For such situations for aluminum derivative HTSUS classifications, where the aluminum country of smelt and cast is required, report “Y” for the secondary country of smelt, and report the country reported as the country of origin of the non-aluminum article as the secondary country of smelt code, and as the country of cast.

For all other fields, continue to follow the CATAIR including reporting on one entry summary line for non-Section 232 entries.

DRAWBACK

No drawback shall be available with respect to the duties imposed pursuant to Proclamation 10895.

FOREIGN TRADE ZONE

Any aluminum articles or derivative aluminum articles, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation and that is 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 HTSUS subheading.

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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