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CSMS # 65236374 - UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
U.S. Customs and Border Protection sent this bulletin at 06/03/2025 06:44 PM EDT
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CSMS # 65236374 - UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
This message provides entry filing instructions for the increased Section 232 steel duties provided for in the Presidential Proclamation issued on June 3, 2025.
BACKGROUND
On June 3, 2025, the President issued a Proclamation , Adjusting Imports of Aluminum and Steel into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862 ) (“Section 232”), increasing from 25 percent ad valorem to 50 percent ad valorem the tariffs previously imposed pursuant to Section 232 on certain imports of steel articles and derivative steel articles from all countries , effective for covered goods entered for consumption, or withdrawn from warehouse for consumption, on and after 12:01am eastern daylight time on June 4, 2025, except for products of the United Kingdom for which the Section 232 tariffs on such imports will remain at 25 percent ad valorem .
See important updates throughout this message on duty rates, effective dates, and Section 232 duties based on the value of steel content for imports classified in Chapter 73.
GUIDANCE
Steel articles and derivative steel articles entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on June 4, 2025, a 50 percent duty rate shall apply to products of all countries except for products of the United Kingdom, to which a 25 percent duty rate applies as specified in the Harmonized Tariff Schedule of the United States (HTSUS) headings below:
9903.81.87/ 9903.81.94 (UK ): Iron or steel products (except derivative articles)
9903.81.88/9903.81.95 (UK): Iron or steel products except for derivative articles that are admitted to a U.S. foreign trade zone under “privileged foreign status” before June 4, 2025, and entered for consumption on or after June 4, 2025 .
9903.81.89/9903.81.96 (UK): Certain derivative iron or steel products (existing steel derivative articles subject to Section 232 prior to March 12, 2025).
9903.81.90/9903.81.97 (UK): Certain derivative iron or steel products (new steel derivative articles classified in Chapter 73 subject to Section 232 on or after March 12, 2025).
9903.81.93 /9903.81.99 (UK): Certain derivative products of iron or steel, (existing derivative steel products, and new derivative steel products in Chapter 73) admitted to a U.S. foreign trade zone under “privileged foreign status” before June 4, 2025 , and entered for consumption on or after June 4, 2025.
With respect to derivative steel articles from all countries (including the UK) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on June 4, 2025, the following HTSUS headings and a 0 percent duty rate applies if the steel was melted and poured in the United States:
· 9903.81.92: Certain derivative steel or iron products (new derivative steel articles on or after March 12, 2025) where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States.
o HTS 9903.81.92 also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before June 4, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after June 4, 2025 (see Foreign Trade Zone section below).
With respect to derivative steel articles entered for consumption, or withdrawn from warehouse for consumption, on or after June 4, 2025, the following HTSUS headings and a 50 percent duty rate applies to products of all countries except for the United Kingdom, and a 25 percent duty rate applies to products of the United Kingdom; these duty rates specifically apply to the value of the steel content within the article :
· 9903.81.91/9903.91.98 (UK): Derivative iron or steel products (new steel derivative articles not classified in Chapter 73 subject to Section 232): the Section 232 duty is on the value of the steel content (see instructions below).
o 9903.81.91/9903.91.98 (UK) also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before June 4, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after June 4, 2025 (see Foreign Trade Zone section below).
· As of June 4, 2025, for all steel and steel derivative articles classified in Chapter 73 that are subject to Section 232 steel duties under any Chapter 99 HTSUS heading, the applicable Section 232 duty is assessed only on the value of the steel content.
Reporting Instructions for Duties Based on Steel Content
For new steel derivatives outside of Chapter 73 subject to Section 232 steel duties, and all steel and steel derivative articles classified in Chapter 73 subject to Section 232 duties , the 50 percent duty (25 percent duty for products of the UK) is to be reported with the Chapter 99 classification based upon the value of the steel content.
If the value of the steel content is the same as the entered value or is unknown, the duty must be reported under the Chapter 99 classification based on the entire entered value, and report on only one entry summary line.
In the case where the value of the steel content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-steel content while the second line will represent the steel content. Each line should be reported in accordance with the below instructions.
Non-Steel content, first line:
Ch 1-97 HTS, this same HTS must be reported on both lines.
Country of origin, same must be reported on both lines.
Total entered value of the article less the value of steel content.
Report the total quantity of the imported goods.
Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties .
Steel content, second line:
Same Ch. 1-97 HTS reported on the first line.
Same country of origin reported on the first line.
Report 0 for quantity for the Ch. 1- 97 HTS.
Report the value of steel content.
Report the Section 232 duties based on the value of steel content with the Chapter 99 HTS.
Report a second quantity (of the steel content) in kilograms with the Chapter 99 HTS.
Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Melt and Pour Reporting Requirements
The reporting of the country of melt and pour and applicability code is mandatory for both steel and steel derivatives. To report the country of melt and pour, importers must report the International Organization for Standardization (ISO) code on steel articles and derivative steel articles subject to Section 232. For steel articles, importer must report the ISO code where the steel was originally melted and poured. For steel derivatives, importers must report the ISO code where the steel was originally melted or “OTH” (for other countries). For products melted and poured in the United States, importers must indicate “US” as the country of melt and pour.
Exclusions and Drawback
Importer-specific product exclusions for Section 232 duties that are active in the Automated Commercial Environment (ACE) shall remain effective until their expiration date or until excluded product volume is imported, whichever occurs first.
No drawback shall be available with respect to the duties imposed.
Foreign Trade Zone (FTZ)
Any steel article or derivative steel article, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation and that is admitted into a U.S. FTZ on or after 12:01 a.m. eastern daylight time on March 12, 2025, must be admitted and granted as “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading.
Any steel article or derivative steel article, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation, and that was admitted into a U.S. FTZ and granted “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on June 4, 2025, will likewise be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTS subheading added by this proclamation.
For steel and steel derivative articles admitted into a U.S. foreign trade zone and granted “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on June 4, 2025, and entered on or after 12:01 a.m. eastern daylight time on June 4, 2025, use the HTS classification below corresponding to the type of imported good:
· 9903.81.88/9903.81.95 (UK): Iron or steel products
· 9903.81.93/9903.81.99 (UK) : Iron or steel derivative products, except as noted below:
o 9903.81.91/9903.91.98: Iron or steel derivative products classified outside of Chapter 73.
o 9903.81.92: Iron or steel derivative products with a melt and pour of United States.
Application of Reciprocal Tariffs under EO 14257
As of June 4, 2025, the non-steel content of an article reported on a separate line per the instructions above is subject to Reciprocal tariffs under HTS 9903.01.25 (see also CSMS # 65201384). The steel content subject to Section 232 duties per the instruction above is not subject to Reciprocal tariffs under HTS 9903.01.33.
Reporting Multiple HTS Numbers
For entry summary lines that include multiple HTS numbers, CBP requires that the duty be appropriately associated to the correct HTS. For example, if the entry is subject to 9903.81.87, then the 25 percent duty must be associated to 9903.81.87 when transmitting to ACE and when a printed 7501 is produced. The 25 percent duty must not be combined with the duty reported on a different HTS within the entry summary line. Further, duties across several required HTS numbers on a given entry summary line must not be combined and cannot be reported on only one HTS within the entry summary line.
CBP expects full compliance from the trade community for accurate reporting and payment of the additional duties. CBP will take enforcement action on non-compliance.
For reference, a summary list of Section 232 Chapter 99 HTSUS classifications is attached.
For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov .
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
steelHTSlist 6.4.25.docx
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