August 18th, 2025 – Effective August 18, 2025, the Department of Commerce will implement modifications under Proclamation 10896 to add additional steel derivative products to the HTSUS, making them subject to Section 232 duties. This guidance provides filing instructions, duty rates, and reporting requirements for importers, including treatment of FTZ entries and reciprocal tariff applications.
Background
Proclamation 10896 (Feb. 10, 2025) adjusts imports of steel into the U.S. under Section 232 of the Trade Expansion Act.
Imposes a 25% ad valorem tariff on certain steel and derivative steel imports from all countries, effective June 23, 2025.
Effective Aug. 18, 2025, additional steel derivative products are added to Annex I of the HTSUS (subject to Section 232 duties).
Annex II makes technical corrections to the HTSUS.
Entry Filing Instructions
Applies to goods entered or withdrawn for consumption on/after Aug. 18, 2025.
Newly-added steel derivative products (see updated HTS list) must be reported under the following Chapter 99 HTSUS numbers:
9903.81.90 (all except UK, subdivision m): 50% duty on steel content.
9903.81.91 (all except UK, subdivision n): 50% duty on steel content. Also applies to FTZ goods admitted under privileged foreign status before Aug. 18, 2025.
9903.81.97 (UK only, subdivision t): 25% duty on steel content.
9903.81.98 (UK only, subdivision u): 25% duty on steel content. Also applies to FTZ goods admitted under privileged foreign status before Aug. 18, 2025.
9903.81.92 (all countries, including UK, subdivisions n/u processed abroad from U.S.-melted & poured steel): 0% duty. Also applies to FTZ goods admitted under privileged foreign status before Aug. 18, 2025.
Reciprocal Tariffs
Non-steel content: subject to HTS 9903.01.25 reciprocal tariffs.
Steel content: not subject to reciprocal tariffs under HTS 9903.01.33.
Drawback
No drawback available on Section 232 steel derivative duties.
Additional Notes
Importers must follow CSMS #65236374 for steel content reporting.
FAQs on Section 232 tariffs provide guidance on melt and pour reporting, determining steel content value, and reporting for goods subject to both steel and aluminum duties.
Read the full updated Steel HTS list here: https://www.tbgfs.com/wp-content/uploads/2025/08/updated-steelhtslist-081525.pdf
Read the full CSMS here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3ee1cba?wgt_ref=USDHSCBP_WIDGET_2
Should you have any questions, please contact our Import Compliance team or call us at 518-785-6000.
