Industry piles on new Section 232 steel derivative inclusion requests

A public comment period is open until 11:59 p.m. ET on Oct. 21. The public can state their support for or opposition to individual inclusion requests at regulations.gov.

Recall President Trump scrapped all previous S232 exclusions upon his return to the White House earlier this year, opting instead for an inclusions process. The first two-week window in May resulted in the addition of over 400 derivative products to the scope of the S232 steel and aluminum tariffs.

Note, for derivative imports, only the steel or aluminum content is tariffed at the current S232 rate of 50% (25% for the UK).

Summaries of inclusion requests related to steel derivatives are shown below. A list of all the HTS codes that were requested for S232 inclusion in this round can be downloaded here.

For a dive into aluminum derivative requests, check out this story from our sister publication, Aluminum Market Update, on how aluminum trade groups are closing gaps in Section 232.

Manufacturer requests

Steel Dynamics Inc. requested the inclusion of 70 items, all of which contain steel as the core component. The ask includes rail sleepers and other track materials (100% steel) and structural columns, beams, and girders (85% steel). Other items on SDI’s extensive request list included mining, agricultural, and textile machinery and equipment, as well as tractor parts, water heaters, fire extinguishers, and machine tools.

U.S. Steel’s request targets can ends and lids made predominantly of steel and integral to tin mill packaging. USS noted that steel’s tiny value per can unit adds up at scale. It flagged its idled tin operations at Gary Works in northwest Indiana and UPI in California, as well as Cleveland-Cliffs’ exit from the tinplate market. It wants derivative S232 protection for the only two remaining US tinplate producers: itself and Ohio Coatings.

Cleveland-Cliffs asked for the inclusion of electrical steel derivative items, including power and distribution transformers, “critical components that power the nationwide electrical grid system.” Almost 25% of the total cost of a transformer comes from grain-oriented electrical steel (GOES). Cliffs, the only remaining GOES producer in the US, additionally highlighted circumvention tactics being used to undermine that market: “These evasion tactics are blatant in the electrical steel market: while there is no electrical steel melting capacity in Mexico or Canada, there are consistent import surges of GOES laminations and cores from these countries into the US market,” as well as rising imports of transformers.

Leggett & Platt has requested the addition of mattress supports, foundations, box springs, and innerspring units — all made mostly of steel. These inclusions would prevent further tariff evasion, as it claims importers are exploiting HTS Chapter 94 classifications to bypass S232 duties.

Guardian Bikes is seeking derivative tariffs on steel and aluminum bicycles, frames, and parts. It also wants special consideration and a specific tariff for imports to protect bicycle manufacturing as it reshores and scales a US industry once lost to overseas markets. (See related story.)

Liberty Safe requested gun safes be added, noting the national security implications tied to firearm storage. Heavy-gauge cold-rolled sheet comprises 53-54% of a safe’s finished weight and up to half of the raw material cost, according to the Payson, Utah-based company. An “onslaught of imports” is eroding the gun safe business, it said, noting, “The erosion of our business, in turn, imperils our suppliers: the US cold-rolled steel sheet industry.”

Union Tank Car Co. asked for S232 coverage of railway tank cars. They are comprised almost entirely of carbon and stainless steel, with each tank containing an average of 40 short tons of steel. The Chicago-based company said steel represents ~95% of the material cost of a finished tank car. Production of these cars has shifted over the past 10 years away from the US. “Mexico is now responsible for the production of most of the critical infrastructure that is required to transport bulk liquids and gases in the United States,” according to the company.

Group requests

The Steel Manufacturers Association (SMA) seeks coverage for derricks, cranes, lifting machinery, and certain motors, noting these sectors drive demand for hot-rolled, cold-rolled, and corrosion-resistant sheet and plate. SMA says closing these loopholes will support downstream demand.

US cold-drawn mechanical tubing producers and chrome processors asked for derivative treatment for cylinder barrels, pumps, and select fluid/pneumatic/mechanical power components made from steel tubes and bars. Tubing producers signing on to the ask include ArcelorMittal Tubular Products, PTC Alliance, Michigan Seamless Tube, Webco Industries, and Sharon Tube Division of Zekelman Industries.

The Committee on Pipe and Tube Imports asked for the inclusion of modular structures with 10-80% steel content, used for LNG and petrochemicals projects.

The Can Manufacturers Institute (CMI) pressed to include filled metal cans made of steel or aluminum. It argues that empty cans are already included under the tariff regime, while cans filled with various food products dodge the S232 tariffs by using food-product HTS codes. Citing plant closures across multiple states and rising input costs for US fillers, it wants filled metal cans included to level the playing field.

The American Fruit & Vegetable Coalition also wants canned fruits and vegetables counted as derivative products. At the same time, it is also pushing for exemptions for tinplate produced by trading allies and required by US can makers. It additionally asked the Department of Commerce to conduct a study on “the impact of steel tariffs and related import policies on U.S. food manufacturing and supply chain stability.”

The Coalition for a Prosperous America (CPA) requested derivative coverage for armored safes, safe deposit lockers, and a series of transformers. It warned that GOES and transformer imports exceed 80% penetration in large units, risking the loss of domestic GOES capacity and grid security.

Pacific Coast Producers seeks the inclusion of bimetal food cans made of tinplate steel. Tinplate costs and tariffs are squeezing US processors, while imports continue to rise, according to the California-based group. It points out that the US became a net food importer in 2023, with significant growth in imports of canned fruit and vegetables from China, South Africa, and South Korea.