Steel and Aluminum Annexes Including HTS Codes for Derivative Items Released

The White House published the annex listing aluminum derivatives that will face additional Section 232 tariffs of 25%, as well as the annex with the steel derivatives that will face 25% tariffs.

For aluminum, 18 of the tariff lines are in Chapter 76, which means the entire value will be tariffed; the other 104 are in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96, and only the aluminum content in those goods will face the tariffs.

For steel, 155 items are in chapter 73; an additional dozen items will only owe duties on the steel content in them, and those are either in chapter 84 or 94. The items in those chapters include bulldozer blades, parts of escalators and elevators, backhoe and front-loader attachments, plows, steel shelving, modular steel building units, brass lighting fixtures and other lighting fixtures.

If the steel in the product was melted and poured in the U.S., or the aluminum was smelted and cast in the U.S., then exported to the country that made the finished good, no tariff would be owed on the finished good.

The notice instructs importers of derivatives of either metal to provide to CBP "any information necessary" to identify the metal content in the product. "CBP is hereby authorized and directed to publish regulations or guidance implementing this requirement as soon as practicable."

The notice does not include an effective date, but says there will be another public notice on when the tariffs will be applied, once systems are in place to collect them.