US Tariffs on Steel Products: Affected Goods and Distinction from Non-Listed Goods

Introduction

The United States has implemented Section 232 trade tariffs on a range of steel products. These measures affect specific headings and subheadings of the Harmonized System (HS) and aim to protect the US steel sector from excessive imports.

This article provides a detailed analysis of the HS headings affected by the US additional tariffs from Chapters 72 and 73 of the HS system and distinguishes them from non-listed headings.

Crucial for the correct customs classification of steel articles are the HS Notes to Section XV as well as to Chapters 72 and 73. They define individual products, their permissible treatments, and their alloys.

Affected HS Headings

The steel products impacted by additional tariffs are listed under specific additional tariff numbers (HTSUS 9903.81.87 to 9903.81.93). These include:

Flat-rolled Products

• HS Headings: 7208, 7209, 7210, 7211, 7212, 7225, 7226

• Included are hot and cold-rolled bands and sheets of iron or steel.

• The definition of these products according to the HS Nomenclature under Note 1 k to Chapter 72 stipulates that flat-rolled products must have a rectangular (not square) cross-section and meet specific thickness-width ratios.

• Excluded are certain alloyed and special coated steel types not falling under these HS headings (for example, precious metal-clad products → Chapter 71).

Bars and Rods

• HS Headings: 7213, 7214, 7215, 7227, 7228

• These headings include rod wire of iron or non-alloy steel (HS 7213), iron or non-alloy steel bars that are only forged, hot-rolled, hot-drawn, or hot-extruded, also twisted after rolling (HS 7214), other bars of iron or non-alloy steel (HS 7215), rod wire of other alloy steels (HS 7227) as well as bars and profiles of other alloy steels and hollow drill bars of alloy or non-alloy steel (HS 7228).

• Bars are defined according to Note 1m to Chapter 72 as solid, non-coiled products with uniform cross-section over the entire length in various geometric forms.

• Wire rod is defined according to Note 1l to Chapter 72 as a hot-rolled, coiled steel product with uniform cross-section, e.g., round, oval, rectangular, or polygonal. It can have surface features like ribs or indentations, e.g., for concrete reinforcement bars.

Profiles (Angles, Shapes, and Sections)

• HS Heading: 7216 (except 7216.61.00, 7216.69.00, and 7216.91.00)

• These include standard profile shapes according to Note 1n to Chapter 72.

• Angles, shapes, and sections made from cold-formed materials are not affected by the additional tariffs

• Profiles are solid products with a consistent cross-section over the entire length that do not meet the definitions of bars or wire. They can be produced by rolling, extruding, drawing, forging, or forming according to Note 1n to Chapter 72.

Wires

• HS Headings: 7217, 7229

• Includes drawn steel wires of different compositions, except special wires for electronic applications.

• Wire is defined according to Note 1o to Chapter 72 as a cold-formed product with consistent cross-section over its entire length, provided in coils or rings.

• Wires under heading 7217 do not include metal yarns and metallized yarns, wire reinforced bind cords and ropes (HS 5605, 5607), coated welding electrodes (HS 8311), saw-toothed wire for card clothing (HS 8448), insulated wires for electrical technology including enameled wires (HS 8544) as well as musical strings (HS 9209).

Tubes and Hollow Profiles

• HS Headings: 7304, 7305, 7306

• Includes seamless and welded pipes of iron or steel.

• Pipes are defined according to Note 9e to Section XV as hollow products with even cross-section over the entire length.

• Not covered under headings 7304, 7305, or 7306 are tubes of iron or steel, even with closures or joints, including thermostatic expansion compensators and expansion joints (HS 8307), as well as exhaust manifolds for internal combustion engines (HS 8409), other parts of machines and appliances of Section XVI, exhaust silencers and tubes for vehicles of Chapter 87 (e.g., HS 8708 or 8714) as well as saddle posts and bicycle frames (HS 8714). Also excluded are pipes that have been processed into recognizably distinct goods and accordingly assigned to different headings.

Semi-finished Products and Raw Materials

• HS Headings: 7206, 7207, 7224

• This includes steel billets, slabs, and pre-rolled products used as raw materials for further processing.

• Semi-finished products are defined according to Note 1 ij) to Chapter 72 as continuously cast or hot-rolled solid products. These products are not coiled.

Stainless Steel Products (Rust-free Products)

• HS Headings: 7218, 7219, 7220, 7221, 7222, 7223

• Includes stainless steel products in all the aforementioned forms

• The definition for stainless steel according to Note 1e to Chapter 72 requires at least 10.5% chromium and a maximum of 1.2% carbon.

Other Derivative Products

• Certain iron and steel products from Chapter 73, such as fasteners (screws, nuts), pipes and pipe fittings, as well as containers and tanks.

Additionally, according to headings 9903.81.89, 9903.81.90, and 9903.81.91 of the HTSUS, from March 12, 2025, all listed imported iron or steel derivative products are subject to additional tariffs, unless they were processed in a different country from steel articles melted and cast in the United States.

This affects the following subheadings (not exhaustive):

This regulation ensures that certain processed steel products from various industries, including construction, agriculture, mechanical engineering, and electrical engineering, also fall under the scope of additional tariffs.

Companies importing such products should consider this when planning their procurement strategy to account for potential additional costs and tariff burdens in the US.

Implications of the Current US Additional Tariff Regulations

On February 10, 2025, a new proclamation was signed, which repeals all previously granted exclusions and quota arrangements for steel imports from March 12, 2025. As a result, all steel imports, regardless of the country of origin, are now subject to a uniform tariff rate of 25%.

Previously, companies could apply for tariff exemptions for certain highly specialized steels, especially if they were not produced in sufficient quantity or quality in the US. These frequently included:

• Tool steels

• Non-rusting special steels for chemical or high-temperature applications

• Silicon-electrical steels for transformers or electric motors

• High manganese steels with more than 1.65% manganese for extreme wear resistance

With the new proclamation of February 2025, the entire exclusion procedure was discontinued, and all previous general tariff exemptions (General Approved Exclusions, GAEs) will be revoked by March 12, 2025. Consequently, even highly specialized steels, which were previously possibly exempt from tariffs, are affected. Company-specific exemptions granted before March 12, 2025, remain valid until their expiration date or until the approved volume is exhausted.

Conclusion

The US additional tariffs affect a wide range of steel products from Chapters 72 and 73, including highly specialized steels for which exemptions previously existed. Since all general exemptions were lifted on March 12, 2025, companies must adjust their import strategies accordingly and consider potential additional costs. A precise delineation and strategic tariff planning are essential to minimize financial risks.