The Bureau of Industry and Security (BIS) will include multiple additional items as steel and aluminum derivative products, which will be subject to the Section 232 measures on their steel and aluminum content.

The BIS’s notice will be published in the Federal Register on August 19, 2025, with the effect of the measure for the additional derivative products, entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August 18, 2025. Only the value of the steel or aluminum content in these derivative products will be subject to the Section 232 tariff, as with the previous list of derivative products.

The notice identifies 407 HTSUS codes as part of the first cycle of the Section 232 Inclusions Process, which started in May 2025. Interested persons may request the inclusion of additional articles incorporating steel and aluminum to Section 232 measures. Such requests can be submitted to the BIS during a two-week period at the beginning of May, September, and January.

The derivative products include various articles containing steel or aluminium, such as air compressors, cables, steel mill rolls, fluid end blocks of hydraulic power pumps, and wind towers as part of a wind-powered electric generating set with nacelles and/or rotor blades. In addition, the measure covers household items, including silverware, knives, forks, spoons, bar stools with metal frames or dining chairs with aluminum frames, dumbbells and kettlebells, as well as filled aerosol packages (i.e., metal containers), e.g. those containing foodstuffs, lubricants, spray paint, perfume, sunscreen, or deodorants. Some tools are also affected, including chain saws, electric hand saws, gas-powered leaf blowers, gas-powered string trimmers, multi-tools, grinders and sanders. And many more. The entire list can be consulted at this link.

The steel derivative articles falling under subdivisions (m/n/t/u) of U.S. Note 16 of the HTSUS are subject to 50 percent duty for all countries, other than the UK, and 25 percent in the case of the UK.  In cases where the derivative iron or steel products, subdivisions (n) or (u), were processed in another country from steel articles that were melted and poured in the United States, they do not attract the Section 232 duty.  See the relevant CBP Guidance.

Similarly, aluminum derivative articles falling under subdivisions (j/k/r/s) of U.S. Note 19 of the HTSUS are subject to 50 percent duty for all countries, other than the UK, and 25 percent in the case of the UK.  Derivative aluminum products listed in subdivisions (j), (k), (r), or (s), which were processed in another country from aluminum articles smelted and cast in the United States, are subject to a 0 percent duty. See the relevant CBP Guidance on the matter.

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Photo of Daniel Cannistra Daniel Cannistra

Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75

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Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75 U.S. antidumping and countervailing duty cases before the U.S. Department of Commerce and the U.S. International Trade Commission under the Tariff Act of 1930. Many of these matters involved appeals to the U.S. Court of International Trade, the U.S. Court of Appeals for the Federal Circuit, binational panels under the North American Free Trade Agreement (NAFTA), and dispute settlement proceedings before the World Trade Organization (WTO). Dan has also represented clients in antidumping proceedings in the European Union, Canada, Mexico, Brazil, India, Thailand, Singapore, Guatemala and Taiwan.

Prior to joining Crowell & Moring, Dan was a director in a national accounting firm providing customs and international trade guidance to multinational clients related to the supply and distribution of goods and services across international borders. Areas of specialization included antidumping and countervailing duties and policy, trade remedies and litigation, free trade agreements and negotiations, classification and valuation, and international trade and development.

Dan’s government appointments include service to U.S. Trade Representative on the roster of international trade practitioners to resolve antidumping disputes involving NAFTA members. For the European Commission, Dan provided advice and training on international trade and antidumping methodology and practice. In addition, Dan has served as an international trade consultant to the governments of Guatemala and Singapore, providing technical advice to these governments on the application of international trade regulations consistent with international law and World Trade Organization agreements and the General Agreement on Tariffs and Trade, Agreement on Antidumping.

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Photo of Vassilis Akritidis Vassilis Akritidis

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive

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To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive compliance and proper corporate governance are essential for success. Vassilis organizes compliance training programs for executives to ensure smooth and cost-effective navigation through the complex web of EU and World Trade Organization regulations.

Vassilis has been practicing EU and international trade law in Brussels since 1991. He qualified in Athens as a maritime lawyer and then pursued graduate studies in European law at the Institute of European Studies in Brussels. An internship at the State Aid Directorate-General for Competition convinced Vassilis that EU and supranational law are hugely interesting. He started as an EU competition and public procurement lawyer and over the years focused increasingly on international trade and WTO law. Vassilis is regularly quoted by renowned legal directories as an expert in these fields.

Vassilis helps his clients win trade investigations, achieve and improve market access, maximize trade benefits, and be trade-compliant wherever they operate. He advises and represents private clients, professional associations, and governments in trade defense investigations (anti-dumping, anti-subsidy, safeguards), customs investigations and litigation, trade sanctions/export controls, and EU anti-fraud investigations led by the European Anti-Fraud Office and the European Public Prosecutor’s Office. Vassilis also advises on EU State aid and EU internal market and public procurement.

Vassilis has worked for clients active in the steel, chemicals, high-tech, transport, defense and aerospace, automotive, and agriculture/food sectors. He represents clients before the EC and other non-EU trade defense authorities.

Should things get contentious, Vassilis is an experienced litigator, representing parties before EU courts in Luxembourg as well as national customs and administrative tribunals.

Vassilis works with his colleagues at Crowell Global Advisors, our global government relations, public policy, and public affairs affiliate, in matters involving EU public policy and lobbying.

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