Published Annexes of Steel and Aluminum EOs Add More Articles for 25% Duties

At a Glance

• On February 14, 2025, President Trump published the executive orders concerning aluminum and steel imports for public inspection in the Federal Register.
• The annexes define additional derivative steel and aluminum articles, which will be subject to 25% duties.

It has been another eventful day in the international trade space. On February 14, 2025, President Trump published the executive orders (EOs) concerning aluminum and steel imports for public inspection in the Federal Register. The text of the EOs is the same as we had previewed earlier that week; the only difference is the addition of the annexes, which define additional derivative steel and aluminum articles that will be subject to 25% duties.

At this time, it does not appear that the definition of steel or aluminum articles will be different from the original Section 232 implementation. However, the definition of steel and aluminum articles is found in the tariff schedule, which may change once U.S. Customs and Border Protection (CBP) publishes its implementation of these orders.

The EO does change the definition of derivative steel and aluminum articles, though. The EO makes clear the 25% duties will apply to the derivative articles previously defined by presidential proclamation, plus additional articles found in the annexes to the EOs. Specifically, the annexes define these additional derivative articles by tariff classification in the Harmonized Tariff Schedule of the United States (HTSUS).

As mentioned on February 12, for steel derivative articles, the 25% duty shall not apply to derivative steel articles processed in another country from steel articles that were melted and poured in the United States. Additionally, for any derivative steel article identified in Annex I that is not in Chapter 73 of the HTSUS, the additional ad valorem duty shall apply only to the steel content of the derivative steel article.

Just as with the steel derivative articles, the 25% duty on derivative aluminum articles shall not apply to derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States. And, just as with steel derivative articles, for any derivative aluminum article identified in Annex I that is not in Chapter 76 of the HTSUS, the additional ad valorem duty shall apply only to the aluminum content of the derivative article. Rules on Russian aluminum have not changed.

For More Information

Please note that we will continue to closely monitor this situation and provide timely updates. In the meantime, please do not hesitate to reach out to a member of the Faegre Drinker Customs and International Trade Team if you have any questions.