Today, the U.S. Department of Commerce released notice of upcoming additions to the list of steel derivative products subject to duties pursuant to Section 232 of the Trade Expansion Act of 1962. Generally speaking, the products include various home appliances including refrigerators, washers, dryers, and food waste disposals. The duties will take effect for such products beginning on June 23, 2025.
Appliances Now Subject to Section 232 Duties
Section 232 of the Trade Expansion Act of 1962 (Section 232) empowers the President to take action to adjust imports of “an article and its derivatives.” In modifying prior Section 232 duty regimes and undertaking new Section 232 investigations, the second Trump Administration has taken a broad view of “derivative” products. In February, the President issued a Proclamation modifying existing Section 232 duties on steel and steel derivative products, which increased the coverage of steel derivative products to 167 eight-digit codes in the Harmonized Tariff Schedule of the United States (HTSUS). A process for petitioning to add further steel derivative products to the list of products subject to Section 232 steel duties was also created, with the first tranche of petitions currently pending review.
Today’s notice leaves existing HTSUS code coverage unchanged and comes in advance of Commerce’s decisions on the first tranche of inclusion petitions. It specifically adds add the following eleven eight-digit HTSUS codes to the list of steel derivative products subject to Section 232 steel duties:
- Combined refrigerator-freezers under HTSUS subheading 8418.10.00;
- Small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
- Washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
- Dishwashers under HTSUS subheading 8422.11.00;
- Chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
- Cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
- Food waste disposals under HTSUS subheading 8509.80.20; and
- Welded wire rack under statistical reporting number 9403.99.9020.
The Section 232 steel duties on these newly added products will be assessed on “the value of the steel content in each product.” The last product in the list was already subject to Section 232 aluminum duties on the value of their aluminum content.
Section 232 steel duties will apply to all newly covered products entered on or after June 23, 2025, including products admitted to a U.S. foreign trade zone under “privileged foreign status” before that date. This expansion of coverage also applies to products of the United Kingdom, at the lower 25% rate.
Government Relations
Cassidy Levy Kent’s attorneys, compliance professionals, economists, and licensed customs brokers have experience assisting clients navigating tariff changes, supply chain challenges, and supply chain tracing through the lens of advocating before decision-makers and government agencies. The tariff regimes imposed that remain subject to revision and adjustment provide opportunities for companies to advocate for their interests. Please contact us with any questions.