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Last week, the U.S. Department of Commerce (Commerce) issued the required certification indicating that the appropriate systems are in place to account for steel and aluminum in derivative products. As a result, the 25% Sec. 232 tariffs have now expanded to cover certain downstream products of both aluminum and steel.

A few important notes:

• The revised Harmonized Tariff System codes published last week indicate only that importers will have to report the steel and aluminum content of derivative products in kilograms, but we are still waiting for additional details.
• There is no "on the water" exclusion or further transition period for the derivative products - the steel and aluminum proclamations state that the 25% duty will be imposed on "goods entered for consumption, or withdrawn from warehouse for consumption, on or after the Commerce certification date."

While the Sec. 232 steel and aluminum tariffs took effect as expected last week, the original announcements deferred the effective date for downstream steel and aluminum derivative products until the Commerce Department certified that "adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue." There remains difficulty in measuring the steel and aluminum content of certain downstream products so that the 25% duty can be applied only to that value.

NMMA remains committed to advocating for policies that protect the recreational boating industry and ensure its continued growth and success

For more information on NMMA’s trade advocacy efforts or to discuss the impact of tariffs on your business, please contact Clay Crabtree, NMMA's Senior Director of Public Policy, at [email protected].