The U.S. Department of Commerce is proposing another expansion of Section 232 tariffs, this time targeting additional downstream products containing steel, aluminum and copper.
The Bureau of Industry and Security (BIS) has proposed adding 14 product categories to the scope of Section 232 duties, potentially extending tariffs to imported goods ranging from electrical cables and fire extinguishers to musical instruments, industrial equipment and trailers.
If finalized, the action could create additional duty exposure for importers that may not traditionally consider themselves steel, aluminum or copper importers.
Products Included in the Proposal
The proposed additions span several industries and product categories, including:
- Aluminum powder
- Brass-wind musical instruments and certain parts and accessories
- Welding machine and apparatus parts
- Floor safes
- Certain electrical conductor cables
- Fire extinguishers
- Heat exchange unit parts
- Certain hydraulic engine and motor parts
- Self-propelled cranes, mobile lifting frames and straddle carriers
- Certain trailers and related products
The proposal demonstrates the continued expansion of Section 232 beyond primary metal imports and into finished and derivative products that incorporate steel, aluminum or copper.
Proposed Tariff Rates
Under Commerce’s proposal, most of the newly identified steel, aluminum and copper derivative products would generally be subject to an additional 25% Section 232 tariff.
Certain products, including cranes, mobile lifting frames and various trailers, would instead be subject to an additional 15% Section 232 tariff.
These rates are proposed and are not yet final. Importers should continue monitoring the rulemaking process for Commerce’s final determination, effective dates and subsequent implementation instructions from U.S. Customs and Border Protection (CBP).
Section 232 Continues to Expand Downstream
The proposal is part of a broader shift in the administration of Section 232 tariffs.
Commerce has established processes allowing additional derivative products to be brought within the scope of Section 232 duties. This means tariff exposure increasingly extends beyond raw or semi-finished metals to finished goods containing steel, aluminum or copper.
BIS has previously expanded Section 232 coverage to hundreds of additional downstream steel and aluminum product classifications. The agency’s inclusion process was created specifically to allow additional derivative articles to be added to the tariff program.
For importers, that makes product classification and material composition increasingly important. A company importing machinery, electrical equipment, safety products or other finished goods could face Section 232 exposure even when metals represent only one component of the imported article.
What Importers Should Do Now
Because the proposed duties cover products across several industries, importers should begin evaluating their potential exposure before the proposal is finalized.
Companies should review the HTS classifications of affected imports, identify products containing steel, aluminum or copper, and determine whether any of the proposed classifications appear in their import activity.
Importers should also consider the potential landed-cost impact of an additional 15% or 25% duty and review supplier agreements and sourcing strategies where significant exposure exists.
It will also be important to watch for CBP implementation guidance explaining how the duties will be reported and calculated for affected entries if Commerce moves forward with the proposal.
Comments and Next Steps
Commerce is accepting public comments on the proposed additions. Companies that import affected products or believe the proposed tariff treatment could significantly impact their operations should review the Federal Register notice and determine whether submitting comments is appropriate.
The proposal is not yet a final tariff action, and additional details may change before implementation.
Alba Wheels Up will continue monitoring the Commerce Department’s Section 232 actions and subsequent CBP guidance.
Importing products that may be affected? Contact Alba, our trade compliance team is here to help.
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