Effective June 4, 2025, the Section 232 tariff on steel and aluminum products increased from 25% to 50% — and the rules for how that rate applies to derivative products changed significantly at the same time. A new category of consumer appliances was also brought under Section 232, effective June 23, 2025.
Key takeaways
- The Section 232 rate on steel and aluminum increased from 25% to 50% on June 4, 2025 (UK goods remain at 25%).
- For derivative products, the 50% now applies only to the steel/aluminum content — but reporting that content split is now mandatory, not optional.
- The non-steel/aluminum portion of a derivative product is subject to the reciprocal or IEEPA tariff based on country of origin — it is no longer automatically exempt from all tariffs.
- Eight categories of consumer appliances are now subject to Section 232, effective June 23, 2025.
- Auto parts and automobiles subject to their own Section 232 (25%) are excluded from the steel/aluminum Section 232, even if their HTS code would otherwise qualify.
How the rate increase changes derivative product calculations
Before June 4, 2025, products already subject to Section 232 from 2020 — such as pipe fittings and metal sheets — paid the 25% Section 232 rate on the entire entered value. The new framework changes that in two important ways.
First, the rate itself is now 50%. Second, that 50% applies only to the steel or aluminum content portion of the product value. If your product contains both steel and non-steel components, you calculate the Section 232 tariff on the metal content only and exclude the rest from that 50% rate.
This content-split approach was previously treated as a privilege — something importers could do to reduce their duty exposure. It is now a requirement. You must identify and declare the steel/aluminum content separately at entry.
What happens to the non-steel/aluminum content?
This is the most important change that many importers initially missed. The non-steel/aluminum portion of a derivative product is not exempt from all tariffs. It is subject to the applicable reciprocal tariff or IEEPA tariff based on the country of origin — the same rates that would apply to any non-Section 232 product from that country.
In practical terms: you now pay 50% on the metal content and the country-of-origin reciprocal/IEEPA rate on the rest. Previously, it was commonly accepted that the non-metal content simply wasn’t taxed under Section 232. That is no longer the case. For a full breakdown of how Section 232 interacts with IEEPA and reciprocal tariffs across different countries, see our post on how tariffs stack.
Consumer appliances now subject to Section 232
The Bureau of Industry and Security (BIS) announced that the following consumer appliance categories are now subject to Section 232 at 50% (or 25% for UK-origin goods), effective June 23, 2025. Importers of these products must split and declare the steel/aluminum content separately at entry.
| Product category | HTS code(s) |
|---|---|
| Combined refrigerator-freezers | 8418.10.00 |
| Dryers (small and large) | 8451.21.00, 8451.29.00 |
| Washing machines | 8450.11.00, 8450.20.00 |
| Dishwashers | 8422.11.00 |
| Chest and upright freezers | 8418.30.00, 8418.40.00 |
| Cooking stoves, ranges, and ovens | 8516.60.40 |
| Food waste disposals | 8509.80.20 |
| Welded wire rack | 9403.99.9020 |
If you import any of these products, effective June 23, 2025, you need to know the steel and aluminum content value as a percentage of the total entered value — and have the documentation to support it. CBP can request your bill of materials, production invoices, and accounting records to verify the reported split.
How does Section 232 interact with auto parts?
If a product is subject to the Section 232 auto parts tariff (25%), it is excluded from the steel/aluminum Section 232 (50%) even if its HTS code falls within the steel/aluminum scope. The auto parts Section 232 takes precedence. Both the steel/aluminum and auto parts Section 232 categories are excluded from the reciprocal tariff. For more on the copper Section 232 which follows the same derivative-content logic, see our post on the Section 232 copper tariff.
Recordkeeping requirements
For any derivative product where you are reporting a metal content split, maintain the following:
- Bill of materials showing steel/aluminum components versus other components
- Supplier invoices for the steel/aluminum materials used in manufacturing
- Accounting documentation substantiating the value allocation
These are the same recordkeeping standards CBP has applied to steel and aluminum derivatives since the tariffs were first introduced, now codified as mandatory rather than optional. For a comprehensive list of the HTS codes that were added to or modified under Section 232 for steel and aluminum, see our post on the 407 new HTS codes added to Section 232.
Frequently asked questions
When did the 50% Section 232 steel and aluminum rate take effect?
June 4, 2025. UK-origin goods remain at the previous 25% rate.
When do the new appliance HTS codes become subject to Section 232?
June 23, 2025, per the BIS announcement.
Do I have to declare the steel/aluminum content separately on my customs entry?
Yes — as of June 4, 2025, reporting the steel/aluminum content split is mandatory for derivative products. You can no longer apply the 50% to the full value or skip the content calculation.
If my appliance has a small percentage of steel content, do I still have to report it?
Yes. There is no de minimis exemption for Section 232 derivative content reporting. Even a small steel/aluminum content value must be declared and is subject to the 50% rate.
Is the non-metal portion of my appliance tariff-free?
No. The non-steel/aluminum value is subject to the applicable reciprocal or IEEPA tariff for the country of origin. Only the Section 232 rate itself is limited to the metal content — the rest of the product still faces tariffs based on origin.
Related reading
- 407 New HTS Codes Added to Section 232 for Steel and Aluminum
- Section 232 Copper Tariff: 50% on Copper and Copper Derivatives Explained
- How Tariffs Stack: Section 232, IEEPA, and Reciprocal Tariffs Explained
- Section 232 changes and how it affects you – importer
- Products exempt from section 232
This article is for general information only and reflects the rules as of its original publication date. Tariff and customs regulations change frequently — consult a licensed customs broker or trade attorney before acting on your specific situation. Contact Simple Forwarding to discuss your shipments.
