407 New HTS Codes Added to Section 232: What Importers Need to Know

The Bureau of Industry and Security added 407 HTS codes to the Section 232 steel and aluminum tariff list, effective August 18, 2025 — expanding the 50% tariff to a wide range of derivative products. If you import anything made with steel or aluminum content, your HTS code may now be on the list.

Key takeaways

407 new HTS codes became subject to the 50% Section 232 tariff starting August 18, 2025.
For derivative products, the 50% tariff applies to the steel or aluminum content only — not the full entered value.
The Section 232-covered portion of a product is exempt from the reciprocal tariff; the remainder is still subject to reciprocal.
The fentanyl tariff (where applicable) applies to the full product value regardless of Section 232 coverage.
Regular HTS code audits — at least every six months — are now essential to catch list expansions and identify duty-saving opportunities.

Which products are now covered?

The BIS announcement was published late on a Friday before a Monday effective date — a pattern worth noting as you set up monitoring workflows. The 407 newly added codes cover derivative products: finished or semi-finished goods that contain steel or aluminum as a material component but are not the raw commodity itself. Think structural assemblies, fittings, enclosures, and similar manufactured items with steel or aluminum content. For context on the underlying 50% rate and product scope, see our post on Section 232 steel and aluminum tariffs.

How the derivative tariff is calculated

This is the nuance most importers miss. For derivative products, the 50% Section 232 tariff applies only to the steel or aluminum content value — not the total entered value. If a part costs $100 and contains $30 worth of aluminum, the 50% tariff applies to that $30, not the full $100. Accurate calculation requires updated supplier certifications breaking out material content values.

How Section 232 interacts with other tariff layers

The three-way interaction between Section 232, reciprocal tariffs, and the fentanyl tariff works as follows:

Section 232 portion vs. reciprocal: The Section 232-covered value is exempt from the reciprocal tariff. The non-steel/non-aluminum remainder is subject to the country-of-origin reciprocal rate.
Fentanyl tariff: Applies to the full product value regardless of Section 232 coverage — no carve-out.

This creates a split-value calculation for many derivative products. Our post on tariff stacking across Section 232, IEEPA, and reciprocal tariffs walks through the math in detail. For copper derivatives now also under Section 232, see our overview of the Section 232 copper tariff.

What to do right now

Cross-reference your current HTS codes against the 407 newly added Section 232 codes.
For any affected products, obtain supplier documentation breaking out steel and aluminum content values.
Review whether any of your covered products might qualify for Section 232 exclusions.
Schedule HTS code audits at least every six months — in today’s environment, the return on a classification review is higher than it’s ever been.

Frequently asked questions

When did the 407 new HTS codes take effect?

August 18, 2025. The BIS published the notice on the preceding Friday afternoon, giving importers minimal lead time to prepare.

Does the 50% Section 232 tariff apply to the full value of derivative products?

No. For derivatives, the 50% applies only to the steel or aluminum content portion of the entered value. Importers must document material content to calculate the correct tariff basis.

Can Section 232 and reciprocal tariffs both apply to the same import?

Partially. The Section 232-covered content is exempt from the reciprocal tariff. The non-steel/non-aluminum portion remains subject to the country-of-origin reciprocal rate. The fentanyl tariff is the exception — it applies to the full product value.

How often should I audit my HTS codes?

At minimum every six months. HTS codes change, tariff lists expand, and ongoing classification research can reveal more accurate and more favorable codes. The payoff on a good audit has never been higher.

Are Section 232 tariffs eligible for duty drawback?

Generally no. Section 232 tariffs — like other IEEPA-based tariffs — are not eligible for duty drawback under the terms of recent executive orders. Confirm the current status with a licensed customs broker for your specific goods.