Do Imported Custom Steel Parts Need to Comply with U.S. National Security Regulations (e.g., Section 232 Tariffs)?

When importing custom steel parts into the United States, compliance with national security regulations is critical. One of the most significant regulations for steel imports is Section 232 of the Trade Expansion Act of 1962, which allows the U.S. government to impose tariffs to protect national security interests.

Yes, imported custom steel parts must comply with U.S. national security regulations, including Section 232 tariffs, which impose duties on steel imports deemed to pose a risk to U.S. national security. ¹

Understanding the impact of these tariffs and how to navigate the regulations is essential for a smooth import process.

How Do Section 232 Tariffs Impact Imported Steel Products?

Section 232 tariffs impose a 25% ad valorem duty on most steel and aluminum imports to protect U.S. national security. These tariffs apply to both raw steel and derivative products, and importers must provide detailed country-of-origin documentation and obtain a steel import license to comply. ²

Section 232 tariffs are designed to protect the U.S. steel industry from foreign competition that could undermine national security. These tariffs apply to a broad range of steel products and have specific requirements that importers must meet to avoid additional costs.

The most notable impact of Section 232 tariffs is the 25% ad valorem duty on most steel products. This includes both raw steel and derivative products, affecting custom steel parts as well.

Key Section 232 Tariff Requirements:

• 25% Tariff: Effective March 12, 2025, a 25% duty applies to most steel imports, including custom steel parts and finished goods.
• Country of Origin Documentation: Importers must provide details on where the steel was “melted and poured,” which is essential to determine tariff applicability.
• Steel Import License: A valid steel import license is required to comply with entry summary filings. This license is obtained through the Steel Import Monitoring and Analysis (SIMA) system.
• Foreign Trade Zones (FTZs): Steel admitted to a U.S. FTZ must be in "privileged foreign status" to avoid Section 232 duties when entering for consumption.
• No Duty Drawback: Section 232 duties are not refundable, even if the goods are later exported.
• No De Minimis Exemption: The Section 321 de minimis exemption generally doesn’t apply to Section 232 duties unless subject to quota restrictions.

Failure to meet these requirements can lead to additional costs, delays, or even denial of entry.

How to Determine Whether Your Products Are Affected by These Tariffs?

To determine if your custom steel parts are subject to Section 232 tariffs, importers should check the Harmonized Tariff Schedule (HTS) code, confirm the country where the steel was “melted and poured,” and review any applicable exemptions for specific products or countries. ³

Determining whether your custom steel parts are affected by Section 232 tariffs requires careful attention to product classification and the country of origin.

Steps to Determine Tariff Applicability:

1. Check the HTS Code: The Harmonized Tariff Schedule (HTS) provides the classification for steel products. If your product falls under a category that is subject to Section 232 tariffs, the 25% duty will apply.
2. Confirm Country of Origin: Provide documentation that shows where the steel was "melted and poured." Steel from certain countries may be subject to specific tariffs, while other countries may be exempt.
3. Review Exemption Lists: Some countries or products may be exempt from Section 232 duties, but these exemptions change over time. Regularly check for updates from the U.S. Department of Commerce and CBP.
4. Consult a Trade Expert: If you're unsure whether your product is subject to Section 232 tariffs, it’s a good idea to consult with a customs broker or trade compliance expert.

By following these steps, you can determine whether your steel parts are subject to Section 232 tariffs.

Are There Ways to Apply for Tariff Exemptions?

Importers can apply for tariff exemptions by submitting a request through the U.S. Department of Commerce’s Section 232 Exclusion Portal. Exemptions are granted for specific products based on lack of domestic availability or national security concerns. ⁴

There are ways to apply for tariff exemptions, but it’s a process that requires careful documentation and adherence to U.S. regulations.

Steps for Applying for Exemption:

1. Request Exemption Through the U.S. Department of Commerce: The U.S. Department of Commerce has a process for submitting exclusion requests. Importers must demonstrate that the steel parts they are importing are unavailable domestically or that the tariffs would harm their business.
2. Provide Necessary Documentation: You’ll need to provide detailed information about the steel parts, including technical specifications and the lack of domestic availability.
3. File the Exclusion Request: The exclusion request is typically submitted through the Section 232 Exclusion Portal, and CBP will review the request and make a determination.

Key Points About Exemption Requests:

• Exemptions are typically granted for specific products, not entire categories.
• The exemption process is lengthy, and not all requests are granted.
• Approved exemptions only apply to the specific product for which the request was made.

Exemption requests must be carefully documented, and approval is not guaranteed, so plan ahead to minimize the impact of tariffs.

How Do Other National Security Regulations Affect Steel Imports?

National security regulations, such as Section 301 investigations and the Defense Production Act, can affect the import of steel products, particularly those used in defense or critical infrastructure. These regulations may impose additional duties or restrictions on certain steel imports. ⁵

Besides Section 232 tariffs, there are other national security regulations that affect steel imports, especially for products deemed critical to defense and infrastructure.

Other National Security Regulations:

• Section 301 and 232 Investigations: These investigations assess the impact of certain imports on U.S. national security. If an import is determined to pose a risk, additional tariffs or trade restrictions may apply.
• Defense Production Act: Steel products used in defense or critical infrastructure may be subject to additional scrutiny and regulation to ensure they meet national security needs.
• Bureau of Industry and Security (BIS) Regulations: BIS, part of the U.S. Department of Commerce, regulates the export of dual-use products (items that have both commercial and military applications) and may impose restrictions on certain steel products.

Steel products used in defense, infrastructure, or critical technologies may be subject to additional regulations, requiring careful compliance management.

Conclusion

Imported custom steel parts must comply with U.S. national security regulations under Section 232 tariffs, which impose a 25% duty on most steel imports. Importers must determine whether their products are affected by these tariffs, provide accurate country-of-origin documentation, and understand the process for applying for exemptions. Staying informed about changes to national security regulations and consulting with trade experts is essential to avoid penalties and ensure smooth importation.

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