The Commerce Department’s Bureau of Industry and Security (“BIS”) published over 90 requests for the inclusion of additional HTSUS subheadings to the list of steel and aluminum derivative products subject to Section 232 tariffs of 50%.
On September 17, 2025, BIS announced a two-week window where parties could submit requests to include additional products to the Section 232 steel and aluminum derivatives lists. Following the closing of the submission window on September 29, 2025, BIS has now published the requests and is soliciting public rebuttal comments.
BIS instituted a process for inclusion of additional products to the list of steel and aluminum derivative articles subject to Section 232 tariffs. BIS indicated it will accept inclusion requests three times annually at the beginning of May, September, and January each year. The September 17, 2025, announcement is the second opportunity for inclusion of requests for expansion of products. Following the first round which closed in May, BIS added 407 subheadings to the list of products subject to Section 232 steel and aluminum derivative tariffs.
We encourage clients to review the comments and identify if they are potentially impacted by the inclusion of additional products to Section 232 steel and aluminum derivatives lists. Affected companies have until October 21, 2025, to submit comments in response to the requests via the Regulations.gov portal and must reference Docket ID BIS-2025-0023.Importers affected by the expansion of the lists of steel and aluminum derivative products subject to Section 232 tariffs should contact their HB attorney and discuss next steps in order to submit comments by the October 21, 2025 deadline.
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