Article by: Rick Walker, Vice President, TradeInsights, LCB/CCS

On March 7, Customs and Border Protection (CBP) issued two significant messages which provided implementation instructions related to the 25% Section tariffs for products classified in Chapters 73 and 76. The announcements listed the reporting requirements for aluminum (CSMS#64348288) and steel (CSMS#64348411). Products classified in these chapters are subject to the 25% tariff on the full value of the imported item.

As you may know, the effective date for the steel and aluminum derivatives that were not classified in chapters 73 or 76 was not clear as it was to be determined by the date the Secretary of Commerce issued a notice that a system was in place to effectively, efficiently and expediently collect the tariffs. Last night, and earlier than expected, the Commerce Department issued a notice certifying that such a system was in place, so the 25% tariff on those goods would also be effective March 12, 2025. It is important to note that as of now, the Commerce Department has not yet published the necessary Federal Register notice but is expected to be issued on March 14. As a reminder, for derivative articles classified outside of chapters 73 and 76, the tariff is only applicable to the portion of steel or aluminum contained in the product. CBP issued two messages last night with reporting instructions.

STEEL

ALUMINUM

Importers with these affected products will need to work closely with their suppliers to gather two main pieces of information and list it on the commercial documents used to make entry:

• the value and weight (in kilograms) of aluminum and steel in their derivative products that do not fall under Chapters 73 or 76.
• Importers must also report certain country of origin information—and declare where the aluminum was smelt (primary and secondary country) and country of most recent cast and, with steel, where the steel was melted and poured.

If the value of the steel or aluminum is unknown, CBP requires that the 25% Section 232 duties be assessed on the full value of the imported product. If the importer is unable to provide that information at the time of entry, we would recommend paying the full 25% tariff and then filing a Post Summary Correction to have the excess duty refunded. This could avoid unnecessary demurrage and storage charges.

We are all watching this very closely and are here to assist you.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions.