This is the third supplemental message to the Presidential Proclamation on Steel and Aluminum, and it covers the process for including additional products in the Section 232 coverage of steel and aluminum derivative products.

The processes in the Presidential Proclamations on Steel and Aluminum for adding products are virtually identical.

• Both Proclamations direct the U.S. Commerce Department to “establish a process for including additional derivative steel { or aluminum } articles within the scope” of the Section 232 tariff regimes.
• Commerce is instructed to complete this process within 90 days after the date of the Proclamations, or by May 12, 2025
• The process will “provide for including additional derivative steel { or aluminum } articles at the request of a producer of a steel article or derivative steel article, or an industry association representing one or more such producers, where the request establishes that imports of a derivative steel article have increased in a manner that threatens to impair the national security or otherwise undermine the objectives” of the Proclamations on Steel and Aluminum.
• Commerce will have 60 days after receipt of a request to issue a determination regarding whether or not to include the derivative steel or aluminum article within the scope of Section 232 coverage.
• Excluded from Section 232 coverage are “derivative steel { or aluminum } articles processed in another country from steel { or aluminum } articles that were melted and poured { or in the case of aluminum, smelted and cast } in the United States.”
• Importers of steel or aluminum derivative articles must provide U.S. Customs and Border Protection (CBP) with the information necessary to identify the steel or aluminum content used in the manufacture of steel or aluminum derivative articles which are imported into the United States.
• The Proclamations refer to additional derivative products that have already been included in the Section 232 coverage, but these derivative products have not yet been identified.  More information may become available when the agencies publish their implementation instructions.

AWPA Counsel will continue to monitor the Administration’s implementation of these Proclamations with respect to including additional derivative steel and aluminum products within the scope of the Section 232 tariff regimes.  We will notify you of any developments.