The Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective April 30, 2025 establishing the process for additional products to be added to the list of steel and aluminum derivatives subject to tariffs under Section 232 of the Trade Expansion Act (“Section 232”).

BIS stated it will accept inclusion requests three times annually at the beginning of May, September, and January each year, with the first such window opening on May 1, 2025.  The submission window will remain open for two weeks, and once open, each submission will be posted for public comment for 14 days.  The first window opened on May 1, 2025.  Submissions of inclusions requests must be submitted via the Defense Industrial Base Programs inbox at DIBPrograms@bis.doc.gov. Public comments on inclusion requests can be submitted at https://www.regulations.gov/​docket/​BIS-2025-0023.

BIS will have 60 days to process and issue final determinations on any requested inclusions.

While the interim final rule is effective immediately, BIS will accept comments on the submissions process through June 16, 2025 at the same web address above.

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