August 18th, 2025 – Effective August 18, 2025, the Department of Commerce will implement modifications under Proclamation 10895 to add additional aluminum derivative products to the HTSUS, making them subject to Section 232 duties. This guidance outlines filing instructions, duty rates, reporting requirements, and special provisions for imports, including those involving Russian-origin aluminum.
Background
Proclamation 10895 (Feb. 10, 2025) directs revisions to the Harmonized Tariff Schedule of the U.S. (HTSUS) to adjust imports of aluminum.
Effective Aug. 18, 2025, additional aluminum derivative products are added to Annex I of the HTSUS and subject to Section 232 duties.
Annex II provides technical corrections to the HTSUS.
Entry Filing Instructions
Applies to imports entered or withdrawn for consumption on/after Aug. 18, 2025.
Newly added aluminum derivative products (see updated HTS list) classified under Chapter 99 HTSUS are subject to the following duties:
9903.85.07 / 9903.85.08 (all except UK): 50% ad valorem duty on aluminum content.
9903.85.09: 0% duty for certain processed articles (j/k/r/s).
9903.85.14 / 9903.85.15 (UK only): 25% ad valorem duty on aluminum content.
Reciprocal Tariffs
Non-aluminum content: subject to HTS 9903.01.25.
Aluminum content (covered under Section 232): not subject to reciprocal tariffs under HTS 9903.01.33.
Russia-Specific Duties
200% duty applies to aluminum/derivative products that are:
Products of Russia,
Contain primary aluminum smelted in Russia, or
Cast in Russia.
Must report under 9903.85.67 (aluminum) and 9903.85.68 / 9903.85.70 (derivative aluminum).
Smelt & Cast Reporting
Importers must report ISO country codes for:
Primary smelt, secondary smelt, and cast country.
If unknown → report “UN,” which triggers 200% Russia duties.
Recycled aluminum: must be documented; report secondary smelt as “Y.”
If smelted/cast in the U.S. → report “US.”
Drawback & FTZ
No drawback available on these duties.
Aluminum/derivative products entering U.S. FTZs (after Aug. 18, 2025) must be admitted under privileged foreign status and remain subject to applicable duties when entered for consumption.
Smelt and cast reporting requirements also apply to FTZ withdrawals.
Read the full updated Aluminum HTS list here: https://www.tbgfs.com/wp-content/uploads/2025/08/updated-aluminumhtslist-081525.pdf
Read the full CSMS here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3ee1ce7?wgt_ref=USDHSCBP_WIDGET_2
Should you have any questions, please contact our Import Compliance team or call us at 518-785-6000.
