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CSMS # 65441222 - UPDATED GUIDANCE: Section 232 Additional Steel Derivative Products

This message updates CSMS #65405824 to list the correct number for pre-existing HTSUS 9903.81.98. No changes were made to the attachment.

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), imposing 25 percent ad valorem tariffs on certain imports of steel articles and derivative steel articles from all countries, effective June 23, 2025. See 90 FR 11249 (March 5, 2025).

On June 3, 2025, the President issued Proclamation 10947, “Adjusting Imports of Aluminum and Steel into the United States,” which imposed an additional 25 percent ad valorem tariff to imports of aluminum and steel articles and derivative aluminum and steel articles (except from the United Kingdom). See 90 FR 24199 (June 3, 2025).

On June 16, 2025, the Commerce Department published a Federal Register notice adding additional steel derivative products to the Annex listing the products subject to Section 232 duties. See 90 FR 25208.

ENTRY FILING INSTRUCTIONS

• Per Federal Register 90 FR 25208, effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on June 23, 2025 the following steel derivative products classified in Chapters 84, 85 and 94 of the Harmonized Tariff Schedule of the United States (HTSUS) are subject to Section 232 duties:

1. combined refrigerator-freezers under HTSUS subheading 8418.10.00;
2. small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
3. washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
4. dishwashers under HTSUS subheading 8422.11.00;
5. chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
6. cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
7. food waste disposals under HTSUS subheading 8509.80.20; and
8. welded wire rack under statistical reporting number 9403.99.9020. (Note that HTSUS 9403.99.9020 is also subject to Section 232 measures on aluminum derivatives articles per Proclamation 10895)

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

• 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 June 23, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after June 23, 2025.
  • 50 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 June 23, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after June 23, 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.
  • HTS 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 June 23, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after June 23, 2025.
  • 0 percent ad valorem duty.

See CSMS # 65236374 for steel content reporting instructions.

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 for derivative products not classified in Chapter 73 or 76, and reporting requirements on goods subject to both steel and aluminum duties.

Drawback

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

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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