Latest Update on the Steel and Aluminum Tariffs: Schedule for the New Section 232.

The International Trade Commission has not yet updated the tariff schedule to include the new tariff provisions. They are expected to be posted on or before March 23, 2018.

The Presidential proclamation for steel and aluminum created new subheadings 9903.80.01 for steel and 9903.82.01 for aluminum.

The subheading specifies a rate of duty set in the applicable subheading plus the new amount as directed by the Presidential Proclamation.  In other words, if the current rate of duty is Free then just the new 10% or 25% would apply.  However, all anti-dumping and countervailing duties that apply will also be imposed. 

In addition, updates to the Annexes will include a new US note 29 to subchapter III of Chapter 99 detailing a new subheading 9903.85.01 that covers aluminum as outlined in the Presidential proclamation:

  • 7601 unwrought aluminum; 
  • 7604 bars, rods and profiles;
  • 7605 wire;
  • 7606 plates, sheets, and strip;
  • 7607 foil;
  • 7608 & 7609 tubes, pipes, and tube or pipe fittings;
  • 7616.99.51 castings and forgings;  

The new subheading 9903.80.01 will cover the steel as outlined on that proclamation. 

Fully covered subheadings:

7206; 7207; 7208; 7209; 7210;7211;7212 ;7213; 7214; 7215; 7217; 7218; 7219; 7220; 7221; 7222; 7223; 7224; 7225; 7226; 7227; 7228; 7229; 7304; 7305; 7306

Partially covered tariffs:

  • 7216: fully covered except cold formed or cold finished angles, shapes, and sections in subheadings 7216.61.00, 7216.69.00 and 7216.91.00;
  • 7301: only subheadings 7301.10.00 for sheet piling is covered. Sub heading 7302.20 for angles, shapes, and sections are not covered; 
  • 7302: fully covered except subheading 7302.30.00 for switch plates, crossing frogs, point rods and other crossing pieces.  All other goods of heading 7302      including railway or tramway rails, fish plates and sole plates, sleepers and other track construction material are covered. 

Each of the annexes gives Customs the ability to require additional information as necessary to administer the new tariff as well as any exemptions. 

In addition, it requires that if Commerce announces any new exemptions, they shall be implemented at the earliest possible opportunity not to exceed five business days after CBP receives any such determination from Commerce. 


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