On August 15, 2025, the Commerce Department’s Bureau of Industry and Security (“BIS”) added 407 Harmonized Tariff Schedule of the United States (“HTSUS”) codes to the list of steel and aluminum derivative products covered by Section 232 tariffs. This change applies to covered products entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern time on August 18, 2025. No exceptions were made for covered products already in transit at that time.
The full list of affected products is available in BIS’s official notice. For these products, the Section 232 tariff—which has been set at 50 percent since June 4, 2025 for all countries except the United Kingdom—applies only to the steel and aluminum content of the product. The non-steel and non-aluminum content of the product remains subject to any reciprocal tariffs imposed by the Trump Administration, as well as any other applicable tariffs. Steel and aluminum imports from the United Kingdom continue to face a 25 percent Section 232 tariff while the two governments finalize provisions of a trade deal framework announced in May.
These additions come as BIS rolls out a formal process allowing companies and industry groups to request the inclusion of additional products under the Section 232 steel and aluminum tariffs. Requests may be submitted during two-week filing windows that open three times a year (at the beginning of January, May, and September). The process is intended to create a transparent pathway for expanding tariff coverage in response to shifting market conditions and domestic industry concerns.
In the first cycle, BIS granted nearly all of the requested additions, declining only 60 HTSUS codes that are already subject to ongoing Section 232 or other trade law investigations. This broad acceptance suggests that future filing rounds may also result in significant expansions of tariff coverage.
Consequently, importers should consider the following steps:
- Review the updated HTSUS list to determine whether their products have been added.
- Update customs entry documentation to ensure product descriptions and material composition are accurately reflected.
- Evaluate whether new tariffs will affect sourcing strategies, pricing models, or supply chains, and adjust accordingly.
The Trump administration has quietly expanded its 50% steel and aluminum tariffs to include more than 400 additional product categories, vastly increasing the reach and impact of this arm of its trade agenda.
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