Do the Aluminum, Iron and Steel Tariffs Apply to Aircraft Parts?

I’ve been getting a lot of questions about the new tariffs on imported aluminum, iron and steel. These new tariffs each impose a 25% duty on imported aluminum, iron and steel. The good news is that they do not apply to everything made of aluminum, iron and steel (so your imported aircraft parts might not be affected). The bad news is that there is a very long list of aluminum, iron and steel goods that are affected by the new 25% tariffs (so your imported aircraft parts might be affected). The worse news is that the process of deciding whether your import is subject to the 25% duty is not easy to navigate.

This blog post is intended to make the navigation process a little bit easier.

The new tariffs impose 25% duties on both raw materials and also articles made from aluminum, iron and steel. This is imposed on all goods of foreign locations (meaning those produced abroad), so it does not apply to products of the United States that are returned to the United States.

In order to navigate the tariffs, you will need to identify the tariff code assigned to your imported goods. Then you will need to compare it to several lists of HTSUS headings and subheadings. If your imported aluminum, iron or steel goods are on any of those lists, then they are probably subject to the 25% duty.

The temporary tariffs on aluminum, iron, and steel are as follows:

Tariff Subheading	Which Goods are Affected?	Duty
9903.85.02	Aluminum Materials described in Chapter 99(III), Note 19, Subdivision (g). This encompasses aluminum materials in a wide variety of forms.	Applicable base duty + 25%
9903.85.04	Derivative Aluminum Goods described in Chapter 99(III), Note 19, Subdivision (i)	Applicable base duty + 25%
9903.85.07	Derivative Aluminum Goods described in Chapter 99(III), Note 19, Subdivision (j)	Applicable base duty + 25%
9903.85.08	Derivative Aluminum Goods described in Chapter 99(III), Note 19, Subdivision (k)	Applicable base duty + 25%
9903.85.09	Derivative Aluminum Goods described in Chapter 99(III), Note 19, Subdivisions (j-k) where the derivative aluminum goods were processed in another country from aluminum articles that were smelted and cast in the United States	Applicable base duty
9903.81.87	Iron/Steel Materials described in Chapter 99(III), Note 16, Subdivision (j). This encompasses iron/steel materials in a wide variety of forms.	Applicable base duty + 25%
9903.81.89	Derivative Iron/Steel Goods described in Chapter 99(III), Note 16, Subdivision (l)	Applicable base duty + 25%
9903.81.90	Derivative Iron/Steel Goods described in Chapter 99(III), Note 16, Subdivision (m)	Applicable base duty + 25%
9903.81.91	Derivative Iron/Steel Goods described in Chapter 99(III), Note 16, Subdivision (n)	Applicable base duty + 25%
9903.81.92	Derivative Iron/Steel Goods described in Chapter 99(III), Note 16, Subdivisions (m-n) where the derivative iron/steel goods were processed in another country from iron/steel articles that were melted and poured in the United States	Applicable base duty

These are chapter 99 temporary tariffs. Each one of them is typically imposed in addition to any other chapter 99 tariffs. So listed steel products of China could be subject to both China-specific tariffs and also steel-specific tariffs (as an example). UPDATE: May of the new chapter 99 tariff codes being published in April 2025 provide an explicit exception for goods subject to the aluminum, iron and steel tariffs. This means that you would apply the aluminum, iron or steel tariff instead of the country-of-origin tariff.

I realize that most can’t identify which goods are affected by the references in the table, above. Therefore I have created lists of affected headings and subheadings with textual descriptions to help guide our readers. These lists are intended to be reasonably complete, but they are also summaries, so you should verify the information suggested by these lists. Also, these lists are based on revision 5 of the HTSUS and the HTSUS is being updated more often than normal, so please verify that the law has not changed!

List One of HTSUS Subheadings and Goods subject to the 25% Tariff on derivative products of iron and steel subject to heading 9903.81.90 (chapter 73 references) and derivative products of aluminum subject to heading 9903.85.07 (chapter 76 references):

• Sheet pilings (HTSUS 7301)
• Railway track material (HTSUS 7302)
• Certain tube or pipe fittings (HTSUS 7307)
• Certain structures (like buildings and bridges and their parts (HTSUS 7308, 7610)
• Reservoirs, tanks and vats (HTSUS 7309)
• Tanks, casks, drums, cans, boxes and similar containers (HTSUS 7310)
• Containers for compressed or liquefied gas (HTSUS 7311)
• Stranded wire, ropes, cables, plaited bands, and slings (HTSUS 7312)
• Barbed wire (HTSUS 7313)
• Cloth (including endless bands), grill, netting and fencing (HTSUS 7314)
• Chain and parts thereof (HTSUS 7315)
• Anchors and grapnels (HTSUS 7316)
• Nails, tacks, pins, and staples (HTSUS 7317) [for these, US-poured steel may not reflect an exception]
• Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, and washers (HTSUS 7318, 7616 [limited applicability])
• Sewing needles, knitting needles, bodkins, crochet hooks, and embroidery stilettos (HTSUS 7319)
• Springs and leaves for springs (HTSUS 7320)
• Stoves and other cooking appliances (HTSUS 7321)
• Radiators (HTSUS 7322)
• Kitchen and household articles (HTSUS 7323, 7615)
• Sinks and baths (HTSUS 7324)
• Luggage frames (HTSUS 7616.99.1000)
• Ladders (HTSUS 7616.99.5130)
• Venetian blinds (HTSUS 7616.99.5140)
• “Other” cast articles (HTSUS 7325)
• “Other” articles (HTSUS 7326, 7616.99.5190)

List Two of HTSUS Subheadings and Goods subject to the 25% Tariff on derivative products of iron and steel (subject to heading 9903.81.91):

• 8431.31.00 certain passenger or freight elevator parts
• 8431.42.00 Bulldozer or angledozer blades
• 8431.49.10 Parts of ships’ derricks or cranes
• 8431.49.90 Parts of equipment like bulldozers and road rollers
• 8432.10.00 Plows
• 8432.90.00 Parts for agricultural equipment
• 8547.90.00 Insulating fittings
• 9403.20.00 Metal furniture (other than office furniture)
• 9405.99.20 Lighting fittings of brass
• 9405.99.40 Lighting fittings made from things other than brass
• 9406.20.00 Prefabricated building modules made from steel
• 9406.90.01 Prefabricated building modules made from things other than wood or steel

List Three of HTSUS Subheadings and Goods subject to the 25% Tariff on derivative products of aluminum (subject to heading 9903.85.08):

• 6603.90.8100 Certain umbrella parts
• 8302.10 Certain base metal mountings
• 8302.20 Castors
• 8302.30 Certain other mountings
• 8302.41 Certain base metal mountings suitable for buildings
• 8302.42 Certain base metal mountings suitable for furniture
• 8302.49 Certain other base metal mountings
• 8302.50 Hat racks and pegs
• 8302.60 Automatic door closers
• 8305.10.0050 Fittings for looseleaf binders
• 8306.30.0000 Ornamental picture frames
• 8414.59.6590 Certain axial fans
• 8415.90.80 Certain air conditioner parts
• 8418.99.80 Certain refrigeration condensing units
• 8419.50.5000 Certain heat exchange units
• 8419.90.1000 Parts of certain water heaters
• 8422.90.0640 Parts of certain dishwashers
• 8424.90.9080 Parts of certain equipment for dispersing liquids or powders
• 8473.30 Parts of certain data processing cases
• 8479.89.9599 Machines not otherwise specified
• 8479.90.8500 Parts for trash compactors
• 8479.90.9596 Parts for machines not otherwise specified
• 8481.90.90 Certain valves
• 8486.90.0000 Semiconductor fabrication machine parts
• 8487.90.0080 Machinery parts not otherwise specified
• 8503.00.9520 Certain parts for motors and generators
• 8508.70.0000 Vacuum cleaner parts
• 8513.90.2000 Battery-powered lamp parts
• 8515.90.2000 Welding machine parts
• 8516.90 Parts of certain heating equipment
• 8517.71.0000 Information transmission device parts (aerials)
• 8517.79.0000 Information transmission device parts (other)
• 8529.90.7300 Certain radar parts
• 8529.90.9760 Certain other non-radar audio-visual parts
• 8536.90.8585 Certain other electrical apparatus for switching or protecting electrical circuits
• 8538.10.0000 certain products for the control or distribution of electricity
• 8541.90.0000 Certain parts of semi-conductor devices
• 8543.90.8885 Parts of certain electrical machines and apparatus
• 8547.90 Certain insulating fittings
• 8708 Parts of certain motor vehicles
• 8807.30.0060 Aircraft parts for use in non-civil aircraft (not propellers and not undercarriages)
• 9013.90 Certain laser parts
• 9401.99.9081 Certain seats
• 9403 Certain metal furniture (other than office furniture)
• 9405.99 Lighting fittings
• 9506 Certain exercise equipment
• 9507 Certain fishing equipment
• 9603.90.8050 Certain brooms

8807.30.0060 is in bold type, above, because it represented aerospace parts, but it is a narrow slice of the field and it does not include civil aircraft parts.