Background

In a Federal Register notice set to publish on Aug. 19, the Bureau of Industry and Security is announcing that 407 new HTSUS subheadings will be added to the list of products covered by the Section 232 actions on steel and aluminum and therefore subject to 50 percent tariffs. These tariffs will be effective for products that are entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on Aug. 18 (i.e., Monday).   

BIS appears to have universally added HTSUS subheadings covered by recent inclusion requests unless the subheading was already covered by a separate Section 232 action or investigation (e.g., on autos/auto parts or trucks/truck parts). According to BIS there are 60 such HTSUS subheadings.

Note that Section 232 tariffs on steel and aluminum apply only to the steel and/or aluminum content of subject products if the product also includes non-steel or non-aluminum content, as applicable. The non-steel and non-aluminum content is subject to “reciprocal” tariffs, which do not apply to the steel and aluminum content if subject to the Section 232 tariffs. Other tariffs may apply to products subject to Section 232 tariffs.

If you have questions or would like to discuss this action further, please contact ST&R.

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