THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE	Department of Commerce Posts Certification of Systems Processing for Steel and Aluminum Tariffs; CBP Posts Implementation of Duties Beginning March 12, 2025
DATE	March 11 2025
AGENCY	Bureau of Industry and Security, Department of Commerce; U.S. Customs and Border Protection
EFFECTIVE DATE	March 12 2025 at 12:01 a.m.
BACKGROUND	President Trump signed Proclamations on February 10 removing country-based and product-based exclusions for steel and aluminum, 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.   The Proclamations required the Secretary of Commerce to certify that adequate systems are in place to process and collect tariff revenue for all covered articles.
DETAILS	The March 11 Notice certifies that adequate systems are now in place to process and collect tariff revenue for covered articles for both steel and aluminum.   Shortly after, CBP issued CSMS Messages # 64384496 and # 64384423, announcing collection of 25% duties on stated steel and aluminum and derivative articles beginning March 12, 2025. The HTS classifications mirror those in the Federal Register notices for steel and aluminum.   We note that for steel derivatives listed in 9903.81.91 and aluminum articles under 9903.85.08 for which the duty only applies to the steel content will need to be entered on 2 lines (line 1 as non-steel/aluminum content; line 2 as value of the steel/aluminum content).   Importers must be able to provide information that may be requested by CBP to prove the content of aluminum or steel in the imported items. If the value of the steel or aluminum is unknown or is the same as the entered value, the duties will be based on the entire value of the derivative steel or aluminum article.   Additionally, importers must report the melt and pour country of the steel and the smelt and cast country of the aluminum.
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	Summary Chart: Section 232 chart Final (1).pdf   The aluminum and derivative aluminum products subject to the additional tariffs in Proclamation 9704 and Proclamation 9980. The steel and derivative steel products subject to the additional tariffs in Proclamation 9705 and Proclamation 9980.    Steel List Aluminum List  A fully searchable spreadsheet based on the Public Inspection Annexes is available here.
CITE	Unpublished Notice – Scheduled to be published March 14 CSMS # 64384423 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products   CSMS # 64384496 – UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products

Recent Trade & Compliance Actions Homepage