Commerce Issues Instructions for Paying Steel and Aluminum Duties

Steel – 25% additional duty. Notice on steel.

Aluminum – 25% additional duty (increase from 10%). Notice on aluminum.

The rules and reporting are increasing in complexity and will continue to do so when the requirements for derivatives become known.

Effective Dates

• March 12, 2025: Steel and aluminum in Chapters 72, 73, 76, derivatives in Chapters 73 and 76, and derivatives outside those chapters on the original list, which are 8708.10.30 and 8708.29.21 for bumper stampings of steel and aluminum.
• TBD: Derivatives outside of Chapters 73 and 76 that are not on the original list. Commerce continues to advise the 25% duty on these products will not be in effect until they publish further guidance.

Key Information

• Chapter 99 HTSUS numbers change – see below. Steel and derivatives on the original list admitted into an FTZ have separate Chapter 99 numbers. Steel and aluminum with U.S. metal content have separate Chapter 99 numbers.
• Country exemptions and general approved exclusions expire after March 11, 2025.
• Product exclusions may be used until they expire or are filled.
• Low value shipments are not exempt.
• Chapter 98 eligibility exempts products from the additional tariff in accordance with the associated benefits, with the exception of HTSUS 9802.00.60. This is a provision for any article of metal manufactured or processed in the U.S. if exported for further processing, and returned to the U.S. for further processing. Normally, duty is assessed upon the value of the processing outside the U.S. These additional duties will be assessed on the full value of the imported article.
• Goods admitted into an FTZ must be admitted as privileged foreign status, unless eligible for admission under domestic status.
• No drawback of these duties will be permitted.
• Derivatives in chapters other than 73 or 76 will be implemented when Commerce determines processes are in place to collect the requisite information to declare metal content by value and weight to apply the duty accordingly.
• Derivatives list is subject to change as Commerce may add products.

HTSUS Numbers

• Existing Chapter 99 HTSUS numbers expire after March 11, 2025.
• New Chapter 99 HTSUS numbers are effective for goods entered on or after March 12, 2025.
• Different Chapter 99 HTSUS numbers are applicable to steel admitted into an FTZ. Steel – HTSUS Chapter 99, Subchapter III, Note 16
• 9903.81.87: Products in Chapter 72 if not being admitted to an FTZ (Replaces 9903.80.01) – Note 16(j)
• 9903.81.88: Products in Chapter 72 if admitted to an FTZ – Note 16(j)
• 9903.81.89: Derivatives on the original list if not being admitted to an FTZ (Replaces 9903.80.03) – Note 16(l)
• 9903.81.93: Derivatives on the original list and new derivatives in Chapter 73 if being admitted to an FTZ – Note 16(l) and (m)
• 9903.81.90: New derivatives in Chapter 73 – Note 16(m)
• 9903.81.91: New derivatives in chapters other than 73 – Note 16(n)
• 9903.81.92: New derivatives in Chapter 73 or other chapters, if the product was processed in another country from steel articles melted and poured in the U.S. – Note 16(m) and (n)

Aluminum – HTSUS Chapter 99, Subchapter III, Note 19

• 9903.85.02: Products in Chapter 76 (Replaces 9903.85.01) – Note 19(g)
• 9903.85.04: Derivatives on the original list (Replaces 9903.85.03) – Note 19(i)
• 9903.85.07: New derivatives in Chapter 76 – Note 19(j)
• 9903.85.08: New derivatives in chapters other than 76 – Note 19(k)
• 9903.85.09: New derivatives in chapter 76 or other chapters, if the product was processed in another country from aluminum articles smelted and cast in the U.S. – Note 19(j) and (k)
• 9903.85.67 – 9903.85.72: Existing HTS numbers for products and derivatives from Russia, or for any amount of primary aluminum is smelted or cast in Russia – Note 19(a)

We will share updates as they become available. Please reach out to your Schenker contact with any questions.