Comments Due October 21 on Requests to Add Hundreds of Products to Steel and Aluminum Tariffs

10.14.2025

The US Department of Commerce recently announced a significant development regarding the Section 232 tariffs on steel and aluminum. On October 7, the Department published 95 new requests to include additional steel and aluminum derivative products under the 50% Section 232 tariffs. These requests are part of the second derivative inclusion process and could have a substantial impact on businesses across various industries. The products include a wide variety of downstream goods, including structural components (beams, girders, columns), can lids, bicycles and frames, safes and lockers, transformer components (grain-oriented electrical steel), mattress supports/box springs, tank cars (railcars), and more.

The new requests aim to add hundreds of tariff schedule lines to the Section 232 tariffs, representing nearly $300 billion in US imports. If approved, this expansion would significantly broaden the range of products subject to these tariffs.

Companies can submit comments in support of or opposition to these requests, but the deadline for such comments is fast approaching: October 21.

As detailed in a prior Client Alert, other significant opportunities for comment on US trade policy are also fast approaching. Requests for additional auto parts to be added to the Section 232 tariffs are due tomorrow, October 15, which will be followed by a two-week comment period. Comments on the Section 232 auto parts inclusion process in general are due on November 3. Comments on the United States-Mexico-Canada Agreement (USMCA) (in advance of a joint review next year) are also due on November 3.

If your business could be impacted by these proposed changes, it is crucial to act quickly to ensure your voice is heard.

Butzel is here to help. We have extensive experience assisting clients in navigating the complexities of Section 232 tariffs, including submitting comments and understanding the potential impact of these changes. For the latest insights and news, please explore our Tariff and Trade Resource Center. Should you have questions or need further guidance, please do not hesitate to contact the authors of this Client Alert or your Butzel attorney.

Jennifer M. Smith-Veluz
202.454.2885
smithveluz@butzel.com

Mitchell Zajac
313.225.7059
zajac@butzel.com

Catherine M. Karol
313.225.5308
karol@butzel.com

Priya Dalal
202.454.2830
dalal@butzel.com

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