Section 232 Aluminum & Steel Tariff
Duty Increase on February 8, 2020

January 28, 2020

Late Friday, January 24, 2020, President Trump issued a formal proclamation authorizing an increase of 10% on duty rates on some derivative aluminum products (Annex I) and an additional 25% on derivative steel products (Annex II). The products included on Annex I and Annex II were not previously subject to the Section 232 duties.

We have now received confirmation of what products are contained on Annex I and II.

How Products are Determined to be Derivative

The new duties will be assessed only on products classified as “derivative” of an aluminum article or steel article if all of the following conditions are present:  

  1. the aluminum article or steel article represents, on average, two-thirds or more of the total cost of materials of the derivative article;
  2. the import volumes of such derivative article increased year-to-year since June 1, 2018, following the imposition of the Section 232 duties.

Aluminum Products Contained in Annex I Subject to Section 232 Duties of 10%

Subheading

Description

7614.10.50

stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles

7614.90.20

stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing comprising electrical conductors, not fitted with fittings or made up into articles

7614.90.40

stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing not comprising electrical conductors, not fitted with fittings or made up into articles

7614.90.50

stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles

8708.10.30

bumper stampings of aluminum, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705

8708.29.21

body stampings of aluminum, for tractors suitable for agricultural use

  • The subheading to be used for reporting the additional duties is 9903.85.03 and applies to all products regardless of the country of origin. 
  • No claim for entry or for any duty exemption or reduction shall be allowed for the derivative aluminum products.
  • No drawback shall be available with respect to the duties imposed on any derivative article.
  • Countries whose products are excluded from the 10% duties are Argentina, Australia, Canada, and Mexico.

Steel Products Contained in Annex II Subject to Section 232 Duties of 25%

Subheading

Description

7317.00.30

nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material excluding such articles with heads of copper),suitable for use in powder-actuated handtools, threaded

7317.00.5503, 7317.00.5505,
7317.00.5507, 7317.00.5560, 7317.00.5580 or
7317.00.6560

nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505,7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65

8708.10.30

bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705

8708.29.21

body stampings of steel, for tractors suitable for agricultural use

  • The subheading to be used for reporting the additional duties is 9903.80.03 and applies to all products regardless of the country of origin.
  • No claim for entry or for any duty exemption or reduction shall be allowed for the derivative aluminum products.
  • No drawback shall be available with respect to the duties imposed on any derivative article.
  • Countries whose products are excluded from the 25% are Argentina, Australia, Brazil, Canada, Mexico, and South Korea.

These additional duties become effective at 12:01am EST on February 8, 2020.

If you have questions about Section 232 duties or other Customs matters, contact George R. Tuttle, III at geo@tuttlelaw.com or at 415-986-8780.

 

George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle.

The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence and may not be considered as such.

Copyright © 2020 by Tuttle Law Offices. 
All rights reserved. 

Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.

 

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