Section 232 Update: 50% Tariff on Aluminum Imports – New Reporting and Classification Rules

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BACKGROUND

On June 3, 2025, the President announced a new proclamation adjusting imports of aluminum and steel into the United States under Section 232 of the Trade Expansion Act. This increases tariffs on certain aluminum articles and derivatives from 25 percent to 50 percent ad valorem, effective at 12:01 AM Eastern Daylight Time on June 4, 2025. However, tariffs on products from the United Kingdom will remain at 25 percent.

Please check for updates on duty rates, effective dates, and Section 232 duties based on aluminum content for imports classified in Chapter 76.

GUIDANCE

Starting June 4, 2025, a 50 percent duty rate will apply to aluminum articles from all countries, except for a 25 percent duty on products from the United Kingdom, as outlined in the Harmonized Tariff Schedule of the United States (HTSUS).

Effective June 4, 2025, a 0% duty rate applies to derivative aluminum articles from all countries (including the UK) entered for consumption, if the aluminum was smelted and cast in the United States.

For aluminum articles entered for consumption or withdrawn from warehouse on or after June 4, 2025, a 50% duty applies to all countries except the United Kingdom, which has a 25% duty. These rates apply to the aluminum content value.

Starting June 4, 2025, Section 232 duties for aluminum articles in Chapter 76 under Chapter 99 HTSUS will be based on the value of the aluminum content.

Reporting Instructions for Duties Based on Aluminum Content

For new aluminum derivatives outside Chapter 76 subject to Section 232 aluminum duties, a 50 percent duty (25 percent for UK products) should be reported with Chapter 99 based on aluminum content value. If the aluminum content value equals or is unknown, report the duty under Chapter 99 using the entire value on one entry line. If the aluminum content value is less than the total value, report on two lines: one for non-aluminum content and one for aluminum content, following the stated instructions.

Non-Aluminum content, first line:

Aluminum content, second line:

Duties for Aluminum from Russia

The 200 percent duty on aluminum products from Russia, or those containing primary aluminum smelted or cast in Russia, remains in effect. This duty applies to the entire value of the imported goods. Importers should report HTS heading 9903.85.67 for aluminum products and 9903.85.68 for derivative aluminum products subject to these duties.

Smelt and Cast Reporting Requirements

To report the primary and secondary countries of smelt for aluminum articles subject to section 232, importers must use the ISO code. Filers should indicate “Y” for the primary and/or secondary country of smelt, but cannot report “N” for both.

If the aluminum is made only from recycled material, report “Y” for the secondary country of smelt, using the country of origin as the code. However, this is uncommon, and importers must provide manufacturing documents if requested.

For derivative aluminum imports, if the country of smelt and cast is unknown, report any country except the United States. Importers can correct this later with the correct information.

If smelted and cast in the U.S., the importer should report “US” for both.

Exclusions and Drawback

Importer-specific product exclusions for Section 232 duties in ACE will remain effective until their expiration date or until the excluded volume is imported. No drawback will be available for the imposed duties.

Foreign Trade Zone (FTZ)

Any aluminum articles and their derivatives, except those eligible for “domestic status” under 19 CFR 146.43, that are subject to duty under this Proclamation and admitted into a U.S. foreign trade zone after the Commerce certification date may only be admitted under “privileged foreign status” as defined in 19 CFR 146.41. Upon entry for consumption, they will be subject to applicable ad valorem duty rates. Smelt and cast reporting requirements will also apply to goods withdrawn from a U.S. FTZ for consumption after June 4, 2025, at 12:01 a.m. Eastern Daylight Time.

Application of Reciprocal Tariffs under EO 14257

As of June 4, 2025, the non-aluminum content of an article is subject to Reciprocal tariffs under HTS 9903.01.25 (See CSMS # 65201384). The aluminum content under Section 232 duties is exempt from Reciprocal tariffs under HTS 9903.01.33.

Reporting Multiple HTS Numbers

For entry summary lines with multiple HTS numbers, CBP requires correct duty association. If an entry is subject to 9903.85.02/9903.85.12(UK), the 25% duty must be linked specifically to those HTS numbers and not combined with duties from other HTS numbers. Duties across required HTS numbers cannot be reported on just one HTS. CBP expects full compliance for accurate reporting and payment of additional duties and will enforce rules on non-compliance.

For reference, you can download a summary list of Section 232 Chapter 99 HTSUS here. Also, click here to read the complete executive order and the CSMS # 65236645 message.

This bulletin is intended for informational purposes only and does not constitute legal or professional advice.

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