Trade Policy Flash: Section 232 nets 407 more "derivative" products
Announced: Friday, Aug 15, 2025 • Effective: Monday, Aug 18, 2025 at 12:01 a.m. ET.
What changed (in plain English)
Scope expanded—big time. Commerce/BIS added 407 HTSUS provisions to the Section 232 lists as "steel" or "aluminum derivative products," reaching far beyond Ch. 72/76 into chemicals, cosmetics, appliances, tools, auto parts, furniture, cutlery, sporting goods and more.
How the duty applies (important nuance)
For these derivative products, the 50% Section 232 duty is assessed on the value of the steel or aluminum content in the article; non-steel/non-aluminum content remains subject to other applicable tariffs (e.g., base MFN, S301 where relevant). BIS codified this allocation in the notes accompanying the new 9903 headings.
No grace period / transit carve-out
CBP guidance indicates coverage starts Aug 18 at 12:01 a.m. ET—practically, that's all entries on/after that timestamp, regardless of ship date.
GHY InternationalFTZ operators
Derivative articles admitted in privileged foreign (PF) status are within scope—there's specific text addressing PF status in the amendments. Don't assume FTZ shields this.
Federal Register Public InspectionWhere this lives legally
BIS posted the public-inspection notice (to be published Aug 19) that implements these additions and technical corrections via HTSUS Annex changes and chapter 99 notes.
Examples you'll actually see in data
The list sweeps in provisions like 8211.91.10 (cutlery) and 0402.99.68 (certain dairy products) through to machinery/electrical and vehicle parts—an unusually broad capture for a "metal" action. Expect hits across product catalogs you'd never previously tied to 232.
Federal Register Public InspectionWhat importers need to do this week
Identify coverage at the 10-digit level
Re-screen SKUs against the new Annex list (and any technical corrections) and tag items with the correct 9903s (e.g., steel: 9903.81.89–.93; aluminum: 9903.85.04/.07/.08/.09).
Federal Register Public InspectionBe BOM-ready
Because the 232 duty applies to the metal content, you'll need traceable valuation of steel/aluminum content (supplier declarations, costed BOMs, or attestation). Build documentation now; CBP will ask.
Federal Register Public InspectionUpdate entry workflows
Make sure brokers have the refreshed HTS/9903 mapping and the content-value allocation method; adjust ABI validations and duty forecasts. CBP has posted 232 inclusion guidance—share it with your brokers.
Check FTZ treatment
PF-status articles aren't exempt—coordinate with zone ops to avoid surprises on weekly entries.
Federal Register Public InspectionReprice & notify
Update landed-cost models and customer pricing where contracts permit. The effective date leaves little room for in-transit mitigation.
GHY InternationalWhy this stings (and we see you)
Importers built 2025 budgets around known 232 lines. With one Friday notice, hundreds of everyday goods suddenly became "metal derivative" for duty purposes—and not at a nominal rate, but at 50% on the metal portion. That's a jolt to margins, cashflow, and ops teams who now need BOM transparency most companies don't have on tap. It's whiplash. You're not overreacting—this is materially disruptive.
What to expect next (prepare now)
More inclusion rounds
BIS created a formal inclusions process with submission windows; this round was Cycle #1. Expect additional batches as petitions funnel in. Keep a standing watchlist and be ready to re-screen SKUs.
Federal Register Public InspectionFurther "technical corrections"
The Aug 15 notice already includes corrections; more cleanup is common after large annex overhauls. Automate how corrections propagate to your ERP.
Federal Register Public InspectionNew sector targets
White House comments hinted at semiconductor actions and further steel adjustments. Budget for spillover measures and keep scenario runs handy (S232/S301 stacking, quotas, carve-outs).
ReutersCountry-specific twists
Watch for smelt/cast/"melt & pour" provenance tightening (Russia-related rules, for example) that can change eligibility day-to-day. Build supplier attestations into POs. (Inference based on recent 232 practice and note language.)
Federal Register Public InspectionBottom line
Effective Aug 18, hundreds of "non-traditional metal" items become Section 232 items, with 50% ad valorem applied to the steel/aluminum content and everything else charged as usual. If you don't have content-value documentation, every entry becomes a fire drill. Get your BOM evidence, supplier certifications, and 9903 mapping in place now.