On Monday, the Department of Commerce announced expanded Section 232 tariffs on steel and aluminum to include 407 additional categories of products being imported to the United States. A range of farm and construction equipment wholegoods, and parts are now included under Section 232 tariffs and subject to a 50% tariff on the value of the steel and aluminum content of the machinery. As of now, our understanding is these tariffs will be stacked on top of the reciprocal country of origin tariffs currently in place.
Under the Department of Commerce rulemaking, the expanded categories include specified Harmonized Tariff Schedule (HTS) codes that include most agricultural and construction machinery, including parts. The codes targeting those product categories include:
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HTS 8433 Harvesting and agricultural machinery and parts
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HTS 8429 Bulldozers, graders, loaders, and excavators
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HTS 8430 Other earthmoving equipment
The Section 232 tariff rate of 50% on the steel and aluminum content of these items now applies to all products imported to the U.S. regardless of country of origin. The only exception is for steel products imported from the U.K. which will be subject to a 25% tariff rate under the recent trade agreement with that country. The USMCA/CUSMA compliant product exemption is still in effect for country of origin reciprocal tariffs, but products meeting those requirements will still be subject to the expanded Section 232 tariff rate.
This marks a major change to the tariff regime. We have contacted the Customs and Border Patrol Agency and numerous customs brokers to clarify information about these tariffs and how they will be applied. At the moment, there is broad confusion and a lack of guidance about how they will be applied and calculated. Your respective manufacturers will most likely be communicating information to you about these tariffs in the near future, and we are discussing their impacts with them.
Unlike previous tariff announcements by the administration that shifted on a moment’s notice, these Section 232 tariffs were created by promulgating agency rules giving them a more permanent footing. NAEDA expects these tariffs to remain in place for the foreseeable future.
Since this remains a very dynamic situation, we will continue providing updates to our dealer members as they become available. Please contact the association with any questions you have about these policy changes.
