In 2025, the U.S. government tightened the rules on steel and aluminum imports. New presidential proclamations imposed tariffs on these metals and certain products made from them.
In simple terms, more goods now fall under Section 232 tariffs. This has made importing steel or aluminum into the U.S. more expensive and closely regulated.
The Section 232 Steel & Aluminum Tariffs now focus less on exclusions and more on inclusion requests. That change affects cost, clearance time, and compliance for any business moving steel, aluminum, or related products across U.S. and Canadian borders.
Understanding how exemptions work and how products get added to the tariff list is now essential. At CustomsCity, we help importers and brokers stay ahead of exactly these changes, before they show up as delays or unexpected costs at the border.
The Big Change: From Exclusions to Inclusion Requests
For years, Section 232 worked on an assumption of relief. If your product did not hurt the U.S. supply, you could ask for an exclusion. Many companies built their compliance playbooks around that idea. It was not perfect, but it gave importers a path to manage costs.
That model ended in 2025.
The government removed the exclusions process and replaced it with an inclusions process. Instead of asking to stay out of the tariffs, industries can now ask the government to pull more products in.
Here is how that shift plays out in real terms:
• Exclusions once allowed companies to argue their products should avoid Section 232 duties. In 2025, that process was shut down completely.
• Inclusion requests now let producers and industry groups expand the tariff list.
• BIS (Bureau of Industry and Security) can add new products without waiting for broad trade negotiations.
• Timelines are shorter now, and decisions move faster.
This change raises the stakes for compliance teams. The tariff scope can grow with little warning. Products that cleared yesterday can trigger duties tomorrow. There is less time to react and less room for classification errors.
Section 232 now rewards preparation and punishes assumptions. That is where the right tools make all the difference. CustomsCity is built to track these regulatory shifts in real time, so your team is not caught off guard when new products enter scope.
What “Steel and Aluminum Derivative Products” Actually Mean
The phrase sounds technical, but the idea is simple. A derivative product is not raw steel or aluminum. It is a finished or semi-finished product that contains steel or aluminum as part of its structure.
That detail matters because many affected products do not look like metal goods at first glance. They look like machines, parts, or tools. But if steel or aluminum plays a functional role in your product, Section 232 can apply.
Common categories now in scope include:
• Industrial machinery and equipment
• Auto and transportation parts
• Tools, hardware, and mechanical components
For many importers, this is where risk creeps in. Products that were once treated as standard manufactured goods may now trigger Section 232 duties. The tariff applies to the steel or aluminum content, not the full product value.
So, if your product contains steel or aluminum, even as one component, it deserves a closer look. Under the current rules, that may be all it takes to bring it into scope.
BIS Added 407 HTSUS Codes: Here’s Why This Matters
In August 2025, the Bureau of Industry and Security expanded the scope of Section 232 by adding 407 HTSUS codes to the list of steel and aluminum derivative products. The change applies to goods entered for consumption on or after August 18, 2025.
From that date forward, these products face Section 232 duties on their steel or aluminum content.
This matters because HTSUS codes drive enforcement at the border. Once a code is added, customs systems apply the tariff automatically. There is no transition period and no manual review to catch the impact ahead of time. For businesses, that shift shows up fast in cost and clearance timelines.
Take an importer bringing in commercial refrigeration units. On the surface, these are finished appliances, not metal products. But the units contain aluminum coils and steel structural components. With the HTS code now added to the Section 232 list, those metal components trigger duties. The importer faces higher landed costs and longer reviews, often without any warning.
CustomsCity’s platform flags these HTS code changes automatically, giving your team the visibility to act before a shipment goes out, not after it stalls at the border.
How Section 232 Duties Are Calculated for Derivative Products
Section 232 duties no longer apply in a simple, all-or-nothing way for derivative products. The government now looks at what your product is made of, not just what it is called.
Here is how it works in practice:
• Section 232 duties apply only to the steel or aluminum content of a derivative product.
• The remaining portion of the product value follows normal tariff rules.
• Other duties still apply to non-metal content.
This makes product valuation far more important. Importers must clearly separate the metal content from the rest of the product and support those numbers with solid documentation. Rough estimates or outdated cost data no longer hold up during review.
This is also where most problems surface. CBP looks closely at declared values, metal percentages, and consistency across filings. When those details do not align, CBP can reject your entries. What starts as a small reporting error can quickly turn into higher duties, delays, or post-entry adjustments.
Compliance Risks That Importers and Brokers Cannot Ignore
If you file entries, manage manifests, or clear freight across the U.S. border, Section 232 now sits in the middle of your daily operations. These risks show up inside filings, timelines, and audits, not just on landed cost spreadsheets.
Misclassification Risk
Products that contain steel or aluminum often move under HTS codes that no longer reflect Section 232 coverage. When classifications lag behind regulatory updates, shipments fall into the wrong duty treatment without anyone noticing at first.
Underpayment of Duties
Missing or undervaluing the steel or aluminum content leads to duties that do not match what CBP expects. These gaps usually surface after release, when corrections become more costly.
Clearance Delays and Holds
CBP flags entries when the metal content, HTS codes, or declared values do not align. Even small inconsistencies can slow release and disrupt delivery schedules.
Post-Entry Corrections and Penalties
Errors tied to Section 232 often require amendments after clearance. This adds rework for brokers and creates financial exposure for importers.
Increased Scrutiny on Metal Declarations
Steel and aluminum shipments now receive closer review, making accuracy and consistency essential across every filing.
Stay Ahead of Section 232 with CustomsCity
Section 232 no longer behaves like a fixed rule set. The shift from exclusions to inclusions means the tariff scope can grow at any time, often without much warning. What cleared smoothly in the past may now trigger duties, delays, or added scrutiny at the border.
This environment rewards preparation. Businesses that review classifications, track metal content, and stay aligned across teams face fewer surprises. Those who wait often end up fixing problems after shipments stall or costs spike.
Section 232 updates arrive fast, and manual compliance struggles to keep pace. When HTS codes shift and metal content rules change, spreadsheets and memory fall short. That is where smarter automation makes a real difference.
CustomsCity combines AI-driven validation with built-in trade expertise to catch issues early. Automated HTS code detection flags products that may fall under Section 232 before filings go out. Integrated duty calculations make it easier to separate steel or aluminum content from the rest of the product value. Real-time visibility across U.S. and Canadian entries helps teams track risk as shipments move, not after problems appear.
The CustomsCity platform supports eManifests, in-bond filings (7512), ISF, Type 11 and 01 entry types, workflows, all backed by 24/7 human support. Compliance tools should do more than manage paperwork. They should protect your margins by reducing errors, delays, and costly surprises at clearance
