On February 14, 2025, the White House released Annex I of the February 10, 2025 Proclamations expanding the Section 232 duties to cover certain additional derivative products of steel and aluminum.  The additional derivative products are identified by Harmonized Tariff Schedule of the United States (“HTSUS”) code in each annex. 

As discussed in our prior update, how the tariffs will be applied depends on the derivative product’s HTSUS classification.  For any derivative article of steel not classified in Chapter 73 of the HTSUS, the additional duty will apply only to the steel content of the derivative steel article.  Likewise, for any derivative article of aluminum not classifiable in HTSUS Chapter 76, the additional duty will apply only to the aluminum content of the derivative aluminum article. 

The effective date for any derivative steel or aluminum articles not classifiable in Chapters 73 or 76 will be the date upon which the Secretary of Commerce issues public notification that “adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.”  All derivative articles classified in Chapters 73 or Chapter 76 will be effective on March 12, 2025.

The Husch Blackwell team is continuing to monitor developments and will provide additional updates as they arise.