Viernes 20 de junio del 2025

The Commerce Department announced this week that it will apply Section 232 steel tariffs beginning June 23 to the value of steel in “derivative” products — specifically, a range of appliances. Separately, a complex “offset” arrangement is being introduced to allow automakers to secure partial rebates for duties paid on U.S.-originating content in imported autos and light trucks.

Duties on “Derivatives.” The 50% ad valorem duties will be applied to the value of the appliances’ steel content, according to a June 16 Federal Register Notice. The process involved may give indications on how other Section 232 tariffs could be applied to “derivative” products.

Appliances affected include refrigerator-freezers; small and large dryers; washing machines; dishwashers; chest and upright freezers; cooking stoves, ranges and ovens; food waste disposals; and welded wire rack. According to the American Iron and Steel Institute, 75% of the weight of a typical household appliance comes from steel on average, though the value is less.

Exclusions Out, Inclusions In: The Commerce Department’s Bureau of Industry and Security in May issued procedures for a new “inclusions process” to add derivative items, which was previewed in the executive order outlining the steel and aluminum duties. The interim final rule directs BIS to establish a submissions window to receive aluminum and steel derivative inclusion requests from industry during two-week submission windows opening three times annually at the beginning of each May, September, and January, with the first such window opening on May 1, 2025.

Auto Tariff “Offset.” Separately, the Commerce Department on June 13 issued procedures for auto manufacturers to apply for a partial rebate — described as an “import adjustment offset amount” — for the 25% Section 232 tariffs applied to imports of autos and auto parts. These duties are applicable to imports of autos and light trucks (since April 3) and auto parts (since May 3, though parts originating in Canada or Mexico and deemed compliant with USMCA are excluded). The process will allow automakers to earn offsets against Section 232 tariffs based on the value of imported vehicles that are built in the United States.

Setting a Precedent? The structure of the program could be extended to other tariff regimes established under Section 232 by the administration. The system solicits a variety of information from manufacturers interested in securing offsets, including aggregate MSRP of autos built on U.S. soil; production forecasts; projected tariff liability (including tariff costs expected to incur); requested offset amount; and a list of importers of record.