Update:
- On August 18, the U.S. Commerce Department expanded the list of steel and aluminum derivative products covered under Section 232 sectoral 50% tariffs, adding 407 new products.
- The duty rate of 50% applies to steel or aluminum content of the derivative products of all countries except the UK, to which a 25% duty rate applies.
- The new rules took effect immediately (August 18) and apply even to goods that were already in transit.
- The tariffs do not apply to steel melted and poured in the U.S. It is unclear at this point whether aluminum smelted and cast in the U.S. is also excluded. We are seeking further clarification on this issue.
For more details, please see Federal Register :: Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process
What products are included:
The expansion goes well beyond raw steel and aluminum. It now covers a wide range of goods that contain these metals, such as:
- Some food packaging (like cans for condensed milk and packaging for food preparations)
- Chemicals, including paints
- Some plastic products (such as windows)
- Certain machinery and equipment (like air compressors, agricultural machinery)
- Furniture and some sports equipment
For such products, 50% tariffs will apply to the steel and aluminum content. The non-steel and non-aluminum content of the product will remain subject to the reciprocal and other applicable tariffs. It is unclear whether the non-steel and non-aluminium content remains exempt under CUSMA. We are seeking further clarification on this issue as well.
What will the process at the U.S. border look like:
- In the case where the value of the steel/aluminium content is less than the entered value of the imported article, the good must be reported to the U.S. Customs and Border Protection (CBP) on two lines.
- The first line will represent the non-steel or non-aluminum content, and include the HTS code, country of origin, entered value and all the tariffs applicable to the good and other information.
- The second line will represent the steel/aluminum content and include details like HTS code, country of melt and pour, value of steel/aluminum content, estimated value of duty based on the value of steel/aluminum content, quantity of steel/aluminum content in kg and any other applicable duties and other information.
For more details, please see CSMS # 65236374 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
Why this matters for Nova Scotia companies:
- Some provincial exports may now face these tariffs, including food preparations and other food items, some plastic products, chemicals, machinery and other items.
- We encourage you to check the updated list of HTS codes HERE to see if it includes the HTS codes you use to export your goods to the U.S.
- We understand that this action introduces a significant new layer of compliance burden and uncertainty for you as exporters. To help you navigate these new requirements, please consider applying for the Tariff and Customs Advisory Program. This program helps Atlantic Canadian companies navigate tariffs, optimize supply chains, and comply with trade regulations. It offers up to 12 hours of expert consulting from customs brokers.
- The Tariff and Customs Advisory Program is delivered by the Nova Scotia Association of Community Business Development Corporations and is an initiative of the Atlantic Trade and Investment Growth Strategy (ATIGS).
