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Several HTS Codes Have Been Removed from the Scope of Section 232 Steel and Aluminum Derivatives

22 Apr 2026

By Richie Lin    Photo:CANVA


For U.S. importers sourcing from Asia, this is not a small technical update. It is a landed-cost issue, a quoting issue, and in many cases, a margin issue. On April 2, 2026, the White House issued a new proclamation modifying the Section 232 tariff regime for aluminum, steel, and certain derivative products. One of the most important changes for importers is this: products listed in Annex II are no longer subject to the additional Section 232 duties under the aluminum and steel proclamations, effective for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on April 6, 2026. CBP also published implementation guidance in CSMS #68253075 on April 3, 2026. https://www.whitehouse.gov/wp-content/uploads/2026/04/ANNEXES-I-A-I-B-II-III-IV.pdf

 

From a 4PL perspective, this means many U.S. importers should stop relying on old tariff assumptions. If your company buys from Taiwan, Vietnam, Thailand, China, or other Asian sourcing bases, you should not assume that a product remains exposed to Section 232 derivative duties simply because it contains metal or was previously discussed as a steel- or aluminum-related item. The proclamation specifically says that some derivative articles should remain covered, while others should no longer be subject because continuing the tariff does not, at this time, significantly contribute to addressing the national security threat identified under Section 232.

 

That distinction is critical. In practical terms, this is no longer just a “metal content” conversation. It is now a classification and scope conversation. Clause (4) of the proclamation states that products listed in Annex II “shall no longer be subject” to the additional duties under the steel and aluminum Section 232 proclamations, while other goods remain in Annex I-A, Annex I-B, or in the temporary reduction list under Annex III. At the same time, the proclamation also confirms that, for products that remain covered, Section 232 can apply to the full customs value of the imported product.

 

For U.S. importers buying from Asia, this creates both opportunity and risk. The opportunity is obvious: some SKUs that were previously treated as tariff-burdened may now be outside the Section 232 derivative scope. The risk is equally obvious: if you continue using outdated broker instructions, ERP tariff assumptions, or supplier quotation models, you may overestimate cost, underquote customers, or miss the chance to rebalance sourcing and inventory decisions.

 

Several importer-relevant HTS lines appear in Annex II. In the electronics and technology space, the removed list includes 8473.30.20.00 for certain parts and accessories of printed circuit assemblies of heading 8471, 8473.30.51.00 for other parts and accessories of machines of heading 8471, 8486.90.00.00 for certain semiconductor manufacturing equipment parts and accessories, 8517.79.00.00 for parts of telecom transmission or reception apparatus, and 8541.90.00.00 for semiconductor device parts. For importers buying technology-related products or components from Asia, those are not minor classifications; they can affect real procurement and inventory decisions.

 

In the furniture and home products sector, Annex II includes 9403.10.00 for metal office furniture, 9403.20.00 for other metal furniture, 9403.99.10.40 for certain metal furniture parts used for motor vehicles, 9403.99.90.40 for metal parts for steel racks, and 9403.99.90.45 for other metal furniture parts. For many U.S. importers sourcing furniture, storage systems, display fixtures, or related components from Asia, this is especially meaningful because these categories often sit right at the intersection of sourcing strategy, warehouse planning, and tariff-sensitive pricing.

 

The list also reaches into sporting goods and recreation products. Annex II includes 9506.51.40.00 lawn-tennis rackets, 9506.51.60.00 racket parts and accessories, 9506.70.20.90 roller skates and related parts, 9506.91.00.10 exercise cycles, 9506.91.00.20 rowing machines, 9506.91.00.30 other gymnasium and exercise equipment parts and accessories, as well as several fishing-reel classifications under 9507.30. If your business imports consumer products, fitness goods, or seasonal retail merchandise from Asia, this is exactly the type of update that should trigger an immediate SKU-by-SKU review.

 

Annex II is not limited to finished consumer goods. It also includes a range of industrial, chemical, and specialty items, such as 2804.29.00.10 helium, 2804.40.00.00 oxygen, and multiple fluorochemical provisions in heading 2903, alongside food and preparation lines such as 0402.99.68, 0402.99.70, 0402.99.90, and 2106.90.99.98. That breadth tells importers something important: this update is not narrowly aimed at one industry. It is a broad scope revision that touches multiple supply chains.

 

At the same time, importers should not interpret this as a blanket rollback of Section 232. The same proclamation leaves many products subject to Section 232, confirms that covered items can be assessed on the full customs value, and establishes Annex III as a temporary reduction list through December 31, 2027, for certain steel and aluminum derivative articles. In other words, some goods were removed, some remain fully covered, and some fall into a reduced-duty framework. That is why broad assumptions are dangerous right now.

 

This is where a professional 4PL approach becomes valuable. A good 4PL does not treat tariff changes as a customs issue only. It connects tariff scope to supplier communication, purchase planning, inventory positioning, and customer pricing. If your sourcing team in Asia is shipping mixed SKU orders, or if your U.S. team is consolidating multiple product categories into one inbound flow, tariff reclassification can change not only estimated duty but also how you prioritize replenishment, allocate inventory, and plan warehouse throughput. A classification change on even a few high-volume SKUs can improve cost visibility and reduce unnecessary buffer pricing. The legal tariff treatment still depends on proper classification and customs entry, but the business response should be operational, not passive.

 

Therefore, what should U.S. importers do immediately? First, review your affected SKU master and identify which items were previously treated as steel or aluminum derivatives. Second, match those SKUs against Annex II, Annex I-B, and Annex III rather than relying on last quarter’s assumptions. Third, confirm entry instructions with your customs broker so treatment aligns with the April 6, 2026, effective date stated in the proclamation. Fourth, update landed-cost models, customer quotations, and sourcing discussions with your Asian suppliers. And finally, make sure your logistics and procurement teams are working from the same classification logic, because tariff savings are often lost when departments work from different data.

 

The real message for U.S. importers is simple: do not assume yesterday’s Section 232 exposure is still today’s reality. Several HTS codes have now been removed from the scope of Section 232 steel and aluminum derivatives, and that creates room for smarter sourcing, more accurate pricing, and better supply chain planning for companies purchasing from Asia. The importers who respond fastest will not just reduce compliance risk. They will turn a regulatory update into a commercial advantage.

 

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