On February 14, 2025, the Trump administration released a list of derivative products that will be subject to a 25% tariff under Section 232 steel and aluminum duties. These products will be officially listed in the Federal Register today Tuesday, February 18, 2025. The specific HTS subheadings for affected steel and aluminum items can be found [here] (steel) and [here] (aluminum).
What We Know…
Affected Products
The new tariffs will impact a wide range of downstream goods, including:
- Most of Chapter 73, covering items such as gazebos, canopies, and similar structures
- Certain household aluminum products
- Steel and aluminum furniture (HTS 9403.20.00)
- Parts for lighting fixtures (HTS 9405.99.40)
- Stoves, ranges, barbecues, and related components (HTS 7321)
- Steel and aluminum cookware
- Aluminum doors, windows, and frames (HTS 7610.10.00)
- Parts for electric water heaters, hair dryers, and similar appliances (HTS 8516.90.8050)
- Some sporting and exercise equipment (HTS 9506, 9507).
Implementation Timeline
These tariffs will not take effect until the Secretary of Commerce confirms that systems are in place to collect the duties. Currently, there is no set deadline for this certification. Additional details on the broader steel and aluminum tariff updates can be found in our previous alert.
The Commerce Department will also develop a process to identify additional derivative products that may be subject to the 25% tariff. Domestic manufacturers can request the inclusion of specific items.
How the Tariffs Will Apply
- For products classified under Chapter 73 or 76, the 25% tariff applies to the full product value.
- For products classified outside these chapters, the tariff will apply only to the steel or aluminum content, not the entire product. However, the notices do not clarify how this content value should be calculated.
The tariff applies only to products classified under the designated HTS subheadings. Items that contain steel or aluminum but fall outside these classifications will not be affected.
Cumulative Duties
- The 25% tariffs will be applied in addition to any other applicable duties. For example, a steel cookware item classified under HTS 7323.93.0045 will face:
- A standard MFN duty of 2%
- 25% Section 232 tariffs
- An additional 10% tariff if imported from China
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