As previously reported, on February 10, 2025, President Trump issued Proclamations 10895 and 10896, making significant changes to the existing measures imposed on imports of aluminum and steel on national security grounds pursuant to Section 232 of the Trade Expansion Act of 1962.  Among other changes, the Proclamations added to the list of so-called “derivative” downstream products incorporating aluminum and steel that would be subject to Section 232 duties of 25 percent for all countries except Russia, which would be subject to duties of 200 percent. 

The new derivative products covered by the February 10 Proclamations are listed in the Annexes to Proclamation 10895 (for aluminum) and 10896 (for steel).  The February 10 Proclamations stated that merchandise listed in the Annexes classified under Chapter 73 (for steel) and Chapter 76 (for aluminum) would be subject to duties beginning on March 12, 2025.  The Proclamations further stated that derivatives classified outside of Chapters 73 and 76 would be subject to the additional duties on the date that the Secretary of Commerce certified that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.

On March 11, 2025, U.S. Secretary of Commerce Howard Lutnick submitted the required certification for publication in the Federal Register.  Later in the evening of March 11, CBP issued updated Cargo Systems Messaging Service guidance previously issued on March 7 for both steel and aluminum to confirm that all derivatives, including those classified outside of chapter 76, would go into effect for entries made on or after 12:01 AM on March 12, 2025. 

At this time, CBP has not provided any guidance on the specific method to be used to declare a value for the aluminum or steel content for affected derivative products.  The Husch Blackwell International Trade Team is monitoring developments closely and will follow up with any further information we receive.