Section 232 Inclusions: An Early Glimpse at the Next Tariff Expansion in the Works
Public comment period ends on 21 October 2025.
The Bureau of Industry and Security published 95 requests to include derivative aluminum and steel products in Section 232 scope.
On 7 October 2025, the Bureau of Industry and Security published 95 requests to include derivative aluminum and steel products in Section 232 scope. These cover 695 HS codes representing $287 billion in US imports (2024).
We extracted all requests, verified HS codes, identified 2024 trade values, and flagged existing S232/IEEPA status.
Our breakdown of the USD 287 billion:
- $125bn already in existing alu/steel S232 scope
- $50bn covered under Auto S232 and thus exempted via "tariff stacking"
- $114bn newly affected US imports
The top product categories are:
- aircraft engine parts ($17bn)
- articles of plastics ($8bn)
- coffee ($2.1bn - the bags), biscuits ($2.1bn - packaging) plus a wide range of canned food.
The Excel file is organised in three sheets: (1) by request number, (2) by HS code, and (3) by exporter - so you can find your exposure quickly.
Why this matters:
Section 232 requires traceability of metal content and (for steel) origin documentation. Even if metal represents only 2-5% of product value (e.g., food packaging), compliance requirements apply to 100% of the supply chain. Read our explainer on Section 232 as a supply chain regulation and different metal-content calculation methods.