CLIENT ADVISORY: Tariffs on New Steel & Aluminum Derivatives Effective March 12,2025.

On March 11, 2025, CBP released after-hours updated guidance announcing start dates of steel and aluminum derivative products outside of Chapters 73 and 76. CBP announced that the 25% Section 232 tariffs on new steel and aluminum derivative products outside Chapters 73 and 76 take effect at 12:01 a.m. Eastern Daylight Time on March 12, 2025. CBP confirmed that the 25% tariff on such derivative products is based upon the value of steel or aluminum content.

CBP clarified that in cases where the value of steel or aluminum content is less than the entered value of the imported article, the good must be reported on two entry declaration lines. The first entry line will represent non-steel or non-aluminum content, while the second entry line will represent steel or aluminum content. Each entry line should be reported in accordance with the instructions provided in the updated guidance on steel and aluminum. We expect CBP to provide additional details concerning the valuation of steel and aluminum content in a separate guidance.

The additional tariffs on steel and aluminum derivative products outside of Chapters 73 and 76 had been on hold until the Secretary of Commerce certified at 4:45 pm on March 11, 2025, “that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles for both steel and aluminum.” This certification process has now been completed thereby allowing for the March 12, 2025 effective date.