New Section 232 Derivative Products
On June 16, 2025, BIS published a Notice in the Federal Register notifying the public that:
- The 232 duty rate for articles of steel and aluminum from all countries except the United Kingdom is 50%.
- The 232 duty rate for articles of steel and aluminum from the UK is 25%
- The following products have been added to the 232 list and are now subject to additional 232 duties: T.
(1) combined refrigerator-freezers under HTSUS subheading 8418.10.00;
(2) small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
(3) washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
(4) dishwashers under HTSUS subheading 8422.11.00;
(5) chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
(6) cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
(7) food waste disposals under HTSUS subheading 8509.80.20; and
(8) welded wire rack under statistical reporting number 9403.99.9020.
Secondary Chapter 99 HTS codes have been created to address the above duty rates. (See CSMS # 65439646 – Harmonized System Update (HSU) 2523).
UPDATE: Section 232 Aluminum Import Instructions for Reporting Unknown for the Country of Smelt and Cast Successfully Deployed
On June 30, 2025, CBP added HTS 9903.85.67 or 9903.85.68, as an option for declaring “Unknown” for the country of smelt or cast for derivative aluminum products. Please remember that aluminum articles subject to 232 duties with an “Unknown” country of smelt or cast will be subject to the 200% Section 232 duties for aluminum articles from Russia.
ENFORCEMENT – Section 232 Letters of Investigation
Many importers have received letters of investigation from the CEE with language like the following:
To Whom it May Concern:
This is to advise you that U.S. Customs and Border protection (CBP) has reasonable cause to believe that violations of 19 U.S.C. 1592 by [COMPANY NAME] have occurred. CBP has initiated an investigation concerning overused Section 232 exclusions by or on behalf of [COMPANY NAME] for possible evasion of Section 232 duties.
We believe these letters are part of CBP’s latest mandate to enforce the new tariffs. If you receive a letter from CBP with this or similar language, we urge you to contact your attorney immediately. If you do not have an attorney, or you have further questions about a possible investigation or the 232 duties in general, please contact us. We are happy to assist.
Cameron Roberts
Jay Acayan
