On March 3, 2025, the Department of Commerce (Commerce) released advanced Federal Register notices providing modifications to the Harmonized Tariff Schedule of the United States (HTSUS) in order to implement the steel and aluminum tariffs announced by the President on February 10, 2025.  Our prior update on these tariffs and the products affected are available here.  The notices will be published in the Federal Register on March 5, 2025 and the tariffs for most articles will go into effect on March 12, 2025.

The notices clarify that steel articles previously subject to Section 232 duties will remain subject to the tariffs, In addition, the modifications provide that derivative steel and aluminum products classified in one of the subheadings of Chapter 73 (steel) or Chapter 76 (aluminum) that were included in the President’s Executive Order will go into effect on March 12, 2025.   Other derivative steel and aluminum products covered by the Executive Order that are classified in subheadings outside of Chapters 73 and 76 will take effect upon public notification by the Secretary of Commerce.