The 25 percent tariff increase the United States imposed on imports of iron and steel, aluminum products and their derivatives from all countries is effective March 12, 2025, according to the Cargo Systems Messaging Service guidance issued by the U.S. Customs and Border Protection (CBP)1 on March 7, 2025.
The main actions established by CBP are as follows:
- CBP provided specific filing instructions for reporting derivatives when the steel or aluminum content is the same, unknown or less than the value of the imported article.
- If the value of the steel or aluminum content is the same as the entered value or is unknown, the duty must be reported under Harmonized Tariff Schedule (HTS) codes 9903.81.91 or 9903.85.08, respectively, based on the entire entered value and reported on only one entry summary line.
- As an example, for the import of a steel coil that is composed entirely of steel, the 25 percent tariff increase will apply to the complete value that is declared in the entry.
- As an example, for the import of a machine that is composed of both steel and non-steel components, if it is not possible to determine the ratio of the steel components and their value, the 25 percent tariff increase will apply to the entire value of the machine.
- If the value of the steel or aluminum content is less than the entered value of the imported article, the good must be reported on two lines. The first line will represent the non-steel or non-aluminum content, while the second line will represent the steel or aluminum content.
- As an example, for the import of a machine that is composed of both steel and non-steel components, if the ratio of the steel components and their value can be determined, the 25 percent tariff increase will apply only to the steel components and their value.
This poses a significant challenge for exporters of goods that contain steel and aluminum in their bill of materials, as it will be necessary to break down the percentage in content and value of these inputs to calculate the 25 percent tariffs imposed by the U.S.
Holland & Knight has extensive experience in customs matters and the complex process of content and origin traceability for proper compliance. Please contact the authors for further information.
Notes
1 The following documents were released by the Cargo Systems Messaging Service:
- CSMS # 64375535 – Quota Guidance: Proclamation 10896 of Feb. 10, 2025, Adjusting Imports of Steel and Aluminum into the United States
- CSMS # 64348411 – GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
- CSMS # 64348288 – GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products
