Customs has issued new guidance on derivative aluminum products entered under Section 232. If the importer does not know the country of smelt and cast, “unknown” (UN) must be reported on the entry. When reporting “unknown” as the country of smelt and cast, provisional codes 9903.85.67 (aluminum products under 232) or 9903.85.68 (derivative aluminum products under 232) must be reported, and the 200% tariffs applicable to Russia will be assessed. According to CSMS #65340246, the effective date for this action is June 28, 2025.
This is a change in procedure, and it will adversely affect some importers of aluminum products that fall under the scope of the Section 232 tariffs. It will be imperative that importers be able to determine the country of smelt and cast for their subject aluminum products moving forward. As of now, there is still no requirement to provide the Certificate of Analysis for derivative aluminum products.
Unfortunately, major changes to the Section 232 tariffs have become all too frequent, and the lead time for these changes has become way too short. Just last week, the Bureau of Industry and Security (BIS) added new products to the list of derivative steel products. These additions included nearly all major household appliances, and they made the additions effective on June 23. The list of these products is below:
(1) Combined refrigerator-freezers under HTSUS subheading 8418.10.00
(2) Small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00653402246
(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
(8) Welded wire rack under statistical reporting number 9403.99.9020
Since interested parties may apply to the BIS to have additional products added to the derivatives lists, it is certain that more additions are coming.
Best Regards,
Sam McClure, LCB
Director of Compliance & Customs Services