Commerce added 407 tariff codes to the Section 232 steel and aluminum derivative list in August 2025, after a public request window that now runs three times a year. The process lets any company or industry group ask the government to tax a specific product it currently imports duty-free, per the Bureau of Industry and Security.
The mechanism sits below the headline-grabbing presidential tariff announcements. It is a standing, recurring channel through which the list of taxed goods keeps growing after the initial proclamation, and it runs almost entirely on paper filed with a federal docket rather than through a new White House action.
Where does this process come from?
The original Section 232 tariffs on steel and aluminum imports took effect March 8, 2018, under national-security authority in the Trade Expansion Act of 1962. On February 10, 2025, Presidential Proclamations 10895 and 10896 expanded those tariffs to cover additional downstream, or "derivative," steel and aluminum products, and a March 12, 2025 action revoked the general exclusions and country-level arrangements that had let some imports avoid the duty.
Once the exclusions were gone, the government still needed a way to handle new products that manufacturers said belonged on the derivative list, or that domestic producers argued were being used to route around the tariff altogether. The Bureau of Industry and Security answered that with a standing, recurring filing process rather than a case-by-case set of one-off rules. BIS established the Section 232 Inclusions Process through an Interim Final Rule effective April 30, 2025, and opened the first submission window on May 1, 2025.
Who can ask for a product to be added?
Any interested party can file a request. BIS accepts submissions through a public docket on the bureau's steel and aluminum program page, identified as Regulations.gov docket BIS-2025-0023, during scheduled two-week windows that open three times a year.
That cadence gives manufacturers, importers and domestic producers a predictable but recurring compliance task: watch for the next window, decide whether a product needs to be added or challenged, and file before the two weeks close. A request is a bet with a clock attached — filing during a window does not guarantee inclusion, and exclusion from one cycle is not always about the merits of the case.
What does Commerce actually decide?
BIS reviews the submissions from each window and determines which products move onto the official derivative list published for that cycle. In the Federal Register notice covering the first window, the agency added 407 Harmonized Tariff Schedule codes to the list and excluded 60 others — not because those 60 failed review, but because they were already subject to other pending Section 232 or trade-remedy investigations.
Once a product is added, the duty is not applied the same way for every item. Depending on how a product is classified under the Harmonized Tariff Schedule, the tariff is calculated either on the full customs value of the finished good or only on the value of the steel or aluminum content inside it, per BIS.
| Step | What happens | Date or interval |
|---|---|---|
| Submission window opens | Interested parties file requests via Regulations.gov docket BIS-2025-0023 | Three two-week windows a year |
| First window | Initial round of requests accepted | Opened May 1, 2025 |
| BIS decision notice | Codes are added to or excluded from the derivative list | Published August 19, 2025 (first cycle) |
| Tariff takes effect | New duty applies to goods entered for consumption or withdrawn from warehouse | August 18, 2025, 12:01 a.m. ET |
When do the new tariffs actually start?
The duties from the first inclusions cycle took effect August 18, 2025, at 12:01 a.m. Eastern time, applying to products entered for consumption or withdrawn from a bonded warehouse after that moment, per the Federal Register notice. Importers with goods already in transit before that cutoff needed to track the exact entry date, since the tariff line depends on when a shipment formally clears customs, not when it left the exporting country.
That gap between a decision notice and an effective date is standard for the process: BIS publishes the outcome of a window, then sets a specific clock-time cutoff, which gives importers only days rather than months to adjust purchase orders, contracts or pricing already in motion.
How does this differ from a full Section 232 investigation?
The inclusions process only expands an existing tariff list. A full Section 232 investigation is a separate, larger undertaking that can create a new tariff program from scratch, covering a product category that was not taxed under the statute before. Under the Trade Expansion Act, it can start three ways: an application from an interested party, a request from the head of a federal department or agency, or self-initiation by the Commerce Secretary, according to BIS.
Once opened, the Secretary has up to 270 days to deliver a report to the president addressing whether the imports under review threaten to impair national security. The president then decides whether to accept the Secretary's recommendations — and if so, can adjust imports of the article and its derivatives or pursue other measures, per BIS's account of the statute. The inclusions process, by contrast, adds products to an already-established tariff without a new investigation, a new national-security finding or a new presidential proclamation. It is maintenance on an existing tariff structure, not the creation of one.
For a company watching either track, the practical difference is speed and predictability. A new investigation can take the better part of a year before a decision even reaches the president's desk. The inclusions process runs on a known calendar — three windows a year — with a defined submission mechanism, even though BIS does not publicly commit to a fixed number of days between a window's close and its decision notice.
For a related manufacturing perspective, read Trump Cuts Steel Tariffs To 25%.
For more context, read Trump Cuts Steel Tariffs To 25%.
For more context, read business.