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16 October 2025

Comments Due October 21 On Requests To Add Hundreds Of Products To Steel And Aluminum Tariffs

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The US Department of Commerce recently announced a significant development regarding the Section 232 tariffs on steel and aluminum.
United States International Law
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The US Department of Commerce recently announced a significant development regarding the Section 232 tariffs on steel and aluminum. On October 7, the Department published 95 new requests to include additional steel and aluminum derivative products under the 50% Section 232 tariffs. These requests are part of the second derivative inclusion process and could have a substantial impact on businesses across various industries. The products include a wide variety of downstream goods, including structural components (beams, girders, columns), can lids, bicycles and frames, safes and lockers, transformer components (grain-oriented electrical steel), mattress supports/box springs, tank cars (railcars), and more.

The new requests aim to add hundreds of tariff schedule lines to the Section 232 tariffs, representing nearly $300 billion in US imports. If approved, this expansion would significantly broaden the range of products subject to these tariffs.

Companies can submit comments in support of or opposition to these requests, but the deadline for such comments is fast approaching: October 21.

As detailed in a prior Client Alert, other significant opportunities for comment on US trade policy are also fast approaching. Requests for additional auto parts to be added to the Section 232 tariffs are due tomorrow, October 15, which will be followed by a two-week comment period. Comments on the Section 232 auto parts inclusion process in general are due on November 3. Comments on the United States-Mexico-Canada Agreement (USMCA) (in advance of a joint review next year) are also due on November 3.

If your business could be impacted by these proposed changes, it is crucial to act quickly to ensure your voice is heard.

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.

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