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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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<img style="max-width: 100%;height: auto" width="825" height="347" src="https://www.thompsonhinesmartrade.com/wp-content/uploads/sites/1018/2025/02/steel-825x347.png" class="attachment-lxb_af_3_of_4-wide size-lxb_af_3_of_4-wide wp-post-image" alt="" />
			On February 14, 2025, the White House released annexes specifying <a href="https://public-inspection.federalregister.gov/2025-02833.pdf" target="_blank" rel="noreferrer noopener">steel</a> (see page 24) and <a href="https://public-inspection.federalregister.gov/2025-02832.pdf" target="_blank" rel="noreferrer noopener">aluminum</a> (see page 19) derivative items that will be subject to the 25% tariffs under Section 232, as announced by President Trump on February 10, 2025. For further details, refer to <a href="https://www.thompsonhinesmartrade.com/2025/02/president-trump-announces-new-tariffs-on-imported-steel-and-aluminum-articles-and-derivatives-from-all-countries-with-no-exemptions-or-exclusions/">our blog post of February 12, 2025</a>.
The items subject to the Section 232 25% tariffs are listed in the annexes according to their 8- or 10-digit Harmonized Tariff Schedule of the United States (HTSUS) codes, without corresponding HTSUS descriptions. The steel derivative annex includes items from HTSUS Chapters 73, 84, 85, and 94. The aluminum derivative annex covers items from Chapters 66, 76, 83, 84, 85, 87, 88, 90, 94, 95, and 96 of the HTSUS.
&ldquo;For purposes of implementing the requirements in [these proclamations], importers of [steel derivative and aluminum derivative articles] shall provide to U.S. Customs and Border Protection within the Department of Homeland Security (CBP) any information necessary to identify the steel content used in the manufacture of steel derivative articles imports, covered by this Proclamation. CBP shall implement the information requirements as soon as practicable.&rdquo;
A public notice will be issued to announce when the tariffs will take effect, once &ldquo;adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.&rdquo;

core/freeform

SmarTrade

Partner

Francesca M.S. Guerrero

Managing Associate

Kristina Shcheglazova

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

White House Releases Annexes of Steel & Aluminum Derivative Items Subject to Section 232 25% Tariffs