The Annexes to the Presidential Proclamations pertaining to the Steel and Aluminum tariffs, which contain the lists of additional HTS numbers for steel and aluminum derivatives which will be subject to additional duty, have been officially published in the Federal Register.
The list of additional aluminum derivative articles can be found here: Additional Aluminum Derivatives . The Annex can be found at the end of the publication.
The list of additional steel derivative articles can be found here: Additional Steel Derivatives .
The Annex can be found at the end of the publication.
As it pertains to the aluminum derivatives listed in the corresponding Annex, for any article NOT classified in chapter 76 of the HTSUS, the additional duty shall be effective “upon public notification by the Secretary of Commerce that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue” for those articles. However, for such articles, the duty shall only be charged on the aluminum content of the derivative article. We have no further information as to the effective date of this clause of the proclamation.
For any article that IS classified in chapter 76 in the aforementioned Annex, it would appear based upon the text of the proclamation, that the duty will be effective as of March 12, 2025 at 12:01 am. However, we await further clarification on this.
In any event, it is important to note that the duty “shall not apply to derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States.” Further, all imports of derivative aluminum articles specified in Annex I that are a product of Russia or where any amount of primary aluminum used in manufacturing the article is smelted in Russia, are subject to a duty rate of 200%.
As it pertains to the steel derivatives listed in Annex I to that proclamation, for any derivative steel article identified in the Annex that is not classified in chapter 73 of the HTSUS, the additional duty shall only apply to the steel content of the article. Similar to aluminum, if the derivative steel article is processed in another country from steel that was melted and poured in the United States, the derivative article is exempt from the additional duty.
Based upon the text of the steel proclamation, it appears that the duty on the additional steel derivative articles specified in the corresponding Annex will be effective “upon public notification by the Secretary of Commerce, that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles” whether or not the derivative article is classified in chapter 73. In other words, it appears there is a slight different between the aluminum and steel proclamations in this respect.
Again, we have no further information or insight as to when “public notification by the Secretary of Commerce” will occur as it pertains to aluminum derivative articles not classified in chapter 76, or all steel derivative articles specified in the Annex. We will advise once we do.