CBP Releases Enforcement Guidelines for 25% Tariffs on Steel and Aluminum Imports

U.S. businesses importing steel and aluminum must verify tariff classifications, provide accurate origin documentation, and adjust their customs reporting to avoid penalties or shipment delays.

As of March 12, 2025, at 12:01 a.m. EDT, the new U.S. tariffs on steel and aluminum imports, including derivative products, are officially in effect.

These 25% tariffs apply to imports from all countries, with all Section 232 tariff rates and absolute quotas expiring on March 11, 2025.

U.S. Customs and Border Protection (CBP) has issued detailed guidance for both steel and aluminum imports and their derivatives to help importers comply with the new duty rates, filing requirements, and exemption criteria.  

Summary of the new tariff updates

Steel and aluminum imports into the U.S. are now subject to a 25% duty under HTS 9903.81.87 (steel) and HTS 9903.85.02 (aluminum)—unless an exemption applies.

Derivative steel and aluminum products will also be included under updated HTS classifications.

Steel and aluminum products admitted into a foreign trade zone (FTZ) under “privileged foreign status” before March 12, 2025, will be assessed at the new 25% tariff rate when entered for consumption.

For aluminum of Russian origin, a 200% duty will apply to any aluminum smelted in Russia or products containing any amount of Russian aluminum.

Guidelines for steel and steel derivative imports

Tariff classifications and rates

• 25% duty rate on the following Harmonized Tariff Schedule of the United States (HTSUS) classifications:
  • 9903.81.87
  • 9903.81.88
  • 9903.81.89
  • 9903.81.90
  • 9903.81.93

• 0% duty on derivatives processed abroad from U.S.-melted and poured steel with the following HTSUS classification:
  • 9903.81.92

Melt and pour reporting requirements

Importers must declare the country where the steel articles and derivative steel articles were originally melted and poured by reporting the International Organization for Standardization (ISO) code.

Exclusions and drawbacks

• Existing importer-specific product exclusions remain valid until expiration or until the specified volume is imported.
• The general approved exclusions (GAEs) expired on March 11, 2025.
• No duty drawbacks are available.

Quotas

• All Section 232 tariff rates and absolute quotas expired on March 11, 2025.
• Entries that did not achieve quota status by 4:30 p.m. local port time on March 11 must be refiled as non-quota entries from March 12, 2025.

Foreign trade zones (FTZs)

• Steel articles and derivatives entering U.S. FTZs on or after March 12, 2025, may be admitted under “privileged foreign status” and are subject to applicable duties upon consumption entry.
• Items granted “privileged foreign status” before March 12, 2025, will also be subject to the new duties upon consumption entry.
• The following HTS classification must be used:
  • 9903.81.88 for iron or steel products (including those classified under GAEs).
  • 9903.81.93 for iron or steel derivative products, except for:
    • 9903.81.91 for iron or steel derivative products classified outside of Chapter 73.
    • 9903.81.92 for iron or steel derivative products with a melt and pour of United States.

Guidelines for aluminum and aluminum derivative imports

Tariff classifications and rates

• 25% duty rate on the following HTSUS classifications:
  • 9903.85.02
  • 9903.85.04
  • 9903.85.07
    
    
• 0% duty on derivatives processed abroad from U.S.-smelted and cast aluminum with the following HTSUS classification:
  • 9903.85.09

Reporting requirements

Importers must use the appropriate ISO codes to report the primary and secondary countries where the aluminum was smelted and cast. 

This information is mandatory for all aluminum articles and derivative products subject to Section 232.

Duties for aluminum from Russia

The 200% duties on any aluminum products and derivative aluminum products subject to Section 232 that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, are still in effect. 

These duties are to be applied on the entire value of the imported goods. Importers should continue to report HTS heading 9903.85.67 for aluminum products and heading 9903.85.68 for aluminum derivative products.

Exclusions and drawbacks

• Existing importer-specific product exclusions remain valid until expiration or until the specified volume is imported.
• The general approved exclusions (GAEs) expired on March 11, 2025.
• No duty drawbacks are available.

Quotas

• All Section 232 tariff rates and absolute quotas expired on March 11, 2025.
• Entries that did not achieve quota status by 4:30 p.m. local port time on March 11 must be refiled as non-quota entries from March 12, 2025.

Foreign trade zones (FTZs)

• Aluminum articles and derivatives entering U.S. FTZs on or after March 12, 2025, may be admitted under “privileged foreign status” and are subject to applicable duties upon consumption entry.
• Items granted “privileged foreign status” before March 12, 2025, will also be subject to the new duties upon consumption entry.
• The smelt and cast reporting requirements also apply to goods entering a U.S. FTZ and withdrawn from the FTZ for consumption on or after 12:01 a.m. EDT on March 12, 2025.

Next steps for steel and aluminum importers

To ensure compliance with the new regulations, importers are advised to take the following steps:

• Review HTS classifications and confirm the correct tariff codes for your imports.
• Adjust filings to reflect new duty rates and ensure proper entry processes.
• Verify country-of-origin documentation to confirm whether your steel and aluminum imports qualify for exemptions or are subject to tariffs.
• Speak to your customs brokers for guidance and support with compliance and reporting.

At Cole International, we offer customs and compliance consulting services to help importers navigate changing regulations. We also provide timely and efficient customs brokerage services for U.S. importers.

Please reach out to one of our trade professionals to discuss the impact of these new tariffs on your business and how we can help you.