Section 232 tariffs are headed downstream

This time, more downstream derivative steel items from Chapter 73, “Articles of iron and steel,” have been added and will face the additional 25% levy.

Think stoves, ranges, grills, butt weld fittings, steel containers, tanks, drums, nails, grinding balls, sewing needles, and barbed wire. Also, structural steels, including flanges, angles, shapes, and sections.

Also included on the list are a handful of items from other HTS chapters, among them: elevators, metal furniture, modular buildings, and lined electrical conduit tubing.

The entire list of derivative steel HTS codes that have been added to the S232 umbrella can be found in the president’s proclamation published in the Federal Register here.

The tariffs will apply to derivative steel products from any and all countries — unless they are made using steel melted and poured in the US.

They will go into effect on March 12.

The declaration also clarified that, for these items and any others added to the list in the future, the additional 25% duty will only apply to the steel content of the derivative article.

Importer beware

It will be up to the importer to provide Customs and Border Protection (CBP) “any information necessary to identify the steel content used in the manufacture of steel derivative articles imports.”

The president’s proclamation directed CBP to “implement the information requirements as soon as practicable.”

Additionally, CBP will be watching for errors in the misclassification of imports.

The president authorized CBP to prioritize reviews of steel and derivatives in order to catch misclassification errors. When found, there will be maximum monetary penalties without any consideration of “mitigating factors.”

If any attempts to evade the additional duties by processing or altering the steel are uncovered, those articles will be considered for addition to the catalog of products covered by the S232 duties.