| THOMPSON COBURN TRADE ALERT – IMPORTS | |
| HEADLINE | Release of Derivative Steel and Aluminum Annexes |
| DATE OF ACTION | 14 February 2025 |
| AGENCY | Trump Administration |
| EFFECTIVE DATE | Removal of country-based exclusions as of March 12, 2025; termination of exclusion process, effective immediately; Duties on new derivative steel or aluminum articles postponed until "public notification by the Secretary of Commerce, that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue on covered articles." |
| BACKGROUND | President Trump signed Proclamations on February 10 and
February 11 removing country-based and product-based exclusions,
terminating the exclusion process, increasing the duties on
aluminum from 10% to 25% and subjecting additional derivative steel
or aluminum articles to the additional duties, as defined in Annex
1. On February 14, 2025, the Administration published a Federal Register Notice for public inspection that provides the relevant annexes, attached to this trade alert. This trade alert also highlights additional compliance concerns regarding the Steel and Aluminum Proclamations. |
| DETAILS | The 25% derivative steel and aluminum Annexes were submitted
for public inspection on 14 February and are scheduled to be
published in the Federal Register on Tuesday 18 February. (The
version that is published on Tuesday will be controlling, if there
are any differences.) Steel Annex I– pages 24-26 There are 155 subheadings in Chapter 73 (entire value subject to tariff) and 12 derivative items in CHs 84, 85, and 94. The non-Chapter 73 derivative items will only owe duty on the steel content they contain. Aluminum Annex I– pages 19-21 There are 18 subheadings in Chapter 76 (entire value subject to tariff) and 104 in chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 or 96. The non-Chapter 76 derivative items will only owe duty on the aluminum content they contain. Importers will be expected to provide to U.S. CBP sufficient information to identify the steel or aluminum content used in the manufacture of the derivative articles covered by each Proclamation. An additional Notice will establish a process for the designation of additional derivative steel or aluminum articles. In addition to analyzing the effect of the removal of the previous Section 232 exclusions based on country of origin, importers should begin assessing the steel and aluminum content in these derivative headings and the associated supply chains, considering whether U.S.-origin aluminum or steel may be used in the processing. It is also recommended that importers consider their exposure with respect to derivative aluminum or steel articles that are not listed in the appendices to these notices, as duties may be assessed on these products with relatively little warning. |
| BASIS | Proclamations of 10 February; Section 232 of the Trade Expansion Act of 1962; 3 U.S.C. 301; 19 U.S.C. 2483 |
| HTS/ PRODUCTS |
A fully searchable spreadsheet based on the Public Inspection Annexes is available here. |
| COUNTRY | All (some exceptions may be negotiated prior to implementation) |
| CITE |
Federal Register :: Adjusting Imports of Steel Into the United
States Federal Register :: Adjusting Imports of Aluminum Into the United States |
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
