Changes to the Duty Rates and the Parts Lists for Aluminum, Steel and Copper Section 232 Tariffs

June 5, 2026 by Leave a comment

If your aluminum, steel and/or copper parts are subject to the special metal derivative tariffs, then the rules surrounding them may be changing.

History

Since April 2, 2026, when the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” certain parts made from aluminum, steel and/or copper have been subject to import duties under special chapter 99 tariffs. That provision imposed the import duties only on parts under certain tariff codes – many aircraft parts made from aluminum, steel and/or copper were not on that list and thus were not subject to these additional duties. But some parts, including some fasteners and other hardware, were subject to these tariffs. The tariffs were issued under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  As a consequence, they were not ruled as illegal with the IEEPA tariffs.

The April proclamation imposed 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles and their derivatives from all countries, effective April 6, 2026. As a base rate, metals were subject to the 50% rate and metal articles (“derivatives”) were subject to the 25% rate. Aircraft parts made from these metals could be considered affected derivatives, if they were listed on the list of affected HTSUS codes.

The Change

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending the April Proclamation. The changes included addition of some new metal parts (“derivatives”) subject to the Section 232 duties, as well as some clarification about reduced rates of duty.

Generally speaking, the duty rate for metals (e.g. bar stock, tubes and pipes, etc.) will be 50%. The duty rate for metal articles will be 25% of the article’s value, except:

  • 15% for products of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union (the total rate of duty – base duty plus additional section 232 duty – shall be 15%);
  • 10 percent for derivative articles where the aluminum and/or steel content was smelted and cast/poured in the United States;
  • For products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement, a duty of 25 percent shall apply only to the non-U.S. content of the product.

A list of the 50% materials is found here.

A list of the 25% articles is found here.

There are technical details and exceptions in addition to what this article covers. If you think your import may be subject to these additional duties then please make sure you scrutinize the standards carefully to ensure you are following the correct compliance path, and are not overpaying your import duties..

The announcement can be found in yesterday’s Federal Register on Page 34085.

These new standards apply to imported parts entered into the United States on or after June 8, 2026.

Looking for more import guidance? Join us at the ASA/AFRA Annual Conference, on June 14-16, in Las Vegas, Nevada. Check out the conference agenda for full details on this and many other workshops available at the conference!

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Importing Compressed Gas in Cylinders

May 14, 2026 by Leave a comment

Imported compressed gas should be declared as a separate line item from the cylinder in which it is contained.

If you are importing a compressed gas (like an oxygen bottle) in a reusable cylinder and need to identify it for import purposes (e.g. on a CBP Form 7501), then you typically will need to declare the gas and the cylinder as two separate line items on the entry declaration.

One reason for this is found in the the HTSUS General Rules of Interpretation, which explains:

5. In addition to the foregoing provisions, the following rules shall apply in respect of the goods referred to therein:
(a) Camera cases, musical instrument cases, gun cases, drawing instrument cases, necklace cases and similar containers,specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and entered with the articles for which they are intended, shall be classified with such articles when of a kind normally sold therewith. This rule does not,however, apply to containers which give the whole its essential character;
(b) Subject to the provisions of rule 5(a) above, packing materials and packing containers entered with the goods therein shall be classified with the goods if they are of a kind normally used for packing such goods. However, this provision is not binding when such packing materials or packing containers are clearly suitable for repetitive use.

Normally, packaging would be merged into the entry for the material contained in the packaging, but for packaging susceptible to multiple uses (“clearly suitable for repetitive use”), that sort of packaging needs to be declared as a separate line item on the import entry.

This issue was addressed in a 2002 Customs Ruling, which involved a reusable steel gas cylinder containing carbon dioxide. The ruling explained that the carbon dioxide must be declared on import (in that case it was identified as HTSUS 2811.21.000) and the reusable steel gas cylinder also needed to be declared as part of the entry (in that case it was identified as HTSUS 7311.00.0090). There is a later ruling that supports this conclusion in a slightly different context: a 2016 Customs Ruling explains that the canisters in which a fire extinguishing agent was contained were to be declared separately from the contained chemical agent.

Today, steel cylinders for compressed gasses will be identified as 7311.00.00xx, where the last two digits depend on the configuration:

  • 7311.00.0030: a steel cylinder certified under the US DOT hazmat rules (Title 49 Part 178) and marked with DOT 3A, 3AX, 3AA, 3AAX, 3B, 3E, 3HT, 3T or DOT-E (including the specific exemption number);
  • 7311.00.0060: a steel cylinder certified under the US DOT hazmat rules (Title 49 Part 178) and but NOT marked according to the standards, above (for example, this could include a DOT 4D cylinder, as found in certain aircraft oxygen bottles);
  • 7311.00.0090: a steel cylinder that is NOT certified under the US DOT hazmat rules.

Aluminum cylinders for compressed gasses will be identified as HTSUS 7613.00.0000.

Some typical gasses (and their HTSUS tariff codes) that might be imported in aviation include:

  • 2804.30.0000: Nitrogen
  • 2804.40.0000: Oxygen
  • 2811.21.0000: Carbon Dioxide

It is important to identify your import with the right tariff code so that it will be subject to the right duties. The tariffs listed above all typically have a non-zero duty attached to them, and the cylinder and the gas may each have different duty rates associated with them.

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New Aluminum, Copper, and Steel Tariffs: Read Carefully Because They May Not Apply to Many Aircraft Parts Imports

April 6, 2026 by Leave a comment

If you are importing aircraft parts made from aluminum, copper and steel then the new aluminum, copper and steel tariffs that go into effect today could have drawn your attention. It is important to look at them carefully because they will apply to a small number of aircraft parts, but they will not apply to most aircraft parts.

Last week, the President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.” That proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective today (April 6, 2026). 

It is important to examine the tariff code for your goods, and compare it to the code listing for the tariff.  NOT ALL PARTS ARE SUBJECT TO THESE DUTIES!  Most bar stock and other non-finished products are covered.  Many wires and fasteners/hardware are covered. 

Many finished aircraft parts made from these materials are not covered; but some aircraft parts may be covered (like certain hydraulic fluid pumps under heading 8413, certain heat exchange units under 8419, and certain bearings under heading 8482 or 8483).  To be certain, it is important to check the annexes, which will be incorporated into the HTSUS.

Once you have identified your imports as being subject to one of these tariffs, then you still need to identify which of the annexes applies (based on tariff number) as well as the source of the material.  The actual calculation mechanism has gotten more complicated and is more fully described in the proclamation and annexes.  For more information, or if you need more guidance, then contact the Association.

Even if the tariff code for your import good is listed, you still need to check the metal content (by weight) because an additional exception may apply.  Goods specified in the annexes to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76, that contain less than 15 percent of the aggregate weight of the applicable metal(s) are not subject to the duties imposed by the Proclamation.  This is the sum of the applicable metals where there is more than one tariffed metal.  For example, since HTSUS is 8302.10.60 is identified in paragraphs (c)(vi) and (vii) of annex IV as both a derivative aluminum article and steel article in annex IV, the aggregate weight of both aluminum and steel (but not copper) should be included in the 15 percent calculation.  If you are able to use the “less than 15% weight” exception, then report it as HTSUS 9903.82.03, and include the aggregate weight of the applicable metal(s) in kilograms as a second quantity on the entry summary line.

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All CBP Refunds Are Now Electronic – Get Your Account Ready If It Isn’t Already Prepared

March 17, 2026 by Leave a comment

Many companies in the ASA community are anticipating refund applications based on the recent Supreme Court case (Learning Resources Inc. v. Trump) that ruled some IEEPA tariffs to be illegal, and the Court of International Trade tariff order directing the duties to be refunded.

There are reports that today, CBP amended its order, to remove the “immediacy” from the requirement to issue refunds. But the refunds still have to be issued. CBP is creating the CAPE system within ACE and has suggested that it could be ready within 45 days of the CIT order (so, mid-to-late-April).

In order to make use of the CAPE system – indeed in order to receive any refund – you will need an ACE account. This is because CBP recently changed the rules to require all refunds to be processed through the ACE system. Some importers rely on their customs broker or their carrier to process all of the imports, and may not yet have an ACE account. If that is your situation, then now is the time to obtain an ACE account.

The expected tariff refund process will be something like this:

  1. File a declaration that itemizes the entries on which you’ve paid IEEPA-based duties; this will be filed within the ACE system (probably within the CAPE subsystem)
  2. The ACE system validates the application against its own data and recalculates the duty owed without the IEEPA tariffs (to verify the refund amount)
  3. CBP verifies the declaration and processes the refunds
  4. CBP liquidates or reliquidates each validated entry
  5. The ACE system should allow CBP to certify that the refund is owed and then the refund will be released by the Treasury
  6. The refund will be deposited in the bank account that you registered for electronic refunds, through your ACE account

U.S. CBP has published a number of resources to assist in obtaining ACE accounts and setting them up to process refunds.

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Tariffs are Illegal – How Do I get My Refund?

February 20, 2026 by 1 Comment

By now, everyone has seen the headline: Many of the tariffs imposed by the Administration have been declared illegal by the Supreme Court in Learning Resources Inc. v. Trump. The Court ruled that the IEEPA did not support issuing those HTSUS Chapter 99 tariffs. Since it was illegal to collect the tariffs, those that have already been collected likely need to be refunded to those who paid them. Many companies in the ASA community paid tariffs and I am sure that those who paid would like to get refunds if it is possible.

It is possible that the administration may create a streamlined mechanism for seeking/issuing tariff refunds. This article describes processes under current law and regulations. We have reached out to the government to seek advice on streamlined filing for refunds, and to offer assistance in streamlining the refund process.

The first step is to assess which tariffs you paid, and which of those were illegal. Not all tariffs were ruled to be illegal – only certain ones. For example, if you imported a bearing last July, and you paid a 9% duty for that bearing under HTSUS chapter 84 PLUS an additional 20% Chapter 99 tariff based on the fact that the bearing’s origin was from the European Union (total of 29% duty), then it is likely that the 9% duty from the base tariff was legal but the 20% duty could be covered under the Supreme Court’s recent ruling.

By and large, the illegal tariffs were issued under HTSUS Chapter 99 so if the basis of the duty that you paid was under another HTSUS chapter then it might have been a legal tariff. Also, some of the HTSUS Chapter 99 tariffs (like steel and aluminum) were issued under other justifications (not under the IEEPA) and those would remain unaffected by today’s ruling.

Once you’ve identified duties that you paid that might be covered by the Supreme Court’s ruling, the next step is to assess whether the import has been liquidated or not. The term Liquidation means the final computation or ascertainment of duties on thing sthat are entered into the United States for consumption. Liquidation usually happens between 300 and 360 days after the import entry (the government aims for an average of 314 days, but our recent assessment found that the average was 330-335 days).

If your import has not yet been liquidated, then you may be able to perform a post-summary correction. Typically this can be accomplished within 300 days of entry but also at least 15 days before liquidation. This is processed through the ACE system. If you discover an error, there is actually a legal obligation to file a correction.

If the 300-day window has passed or the entry has been liquidated, then you can no longer file a post summary correction. Instead, you may be able to file a protest. Protests typically are required to be filed within 180 days of liquidation.

Protests are filed using CBP Form 19. You can file this as a paper form (in which case it must be filed in quadruplicate, and sent to the Port Director) or you can file it online through ACE. If you file a paper copy then we usually advise that you send a fifth copy and a self-addressed stamped envelope in order to get a date-stamped copy back from CBP (as proof of receipt). The filing is considered filed when it is received (not when it is mailed) so make sure it gets to the destination on time!

When you file CBP Form 19, you need to be as specific as you can be. Make sure you provide this information:

  • Identify what is wrong
  • Explain why it is wrong
  • Provide evidence
  • Explain what the corrected entry should be

In the online/electronic form the space to provide this information is small, so don’t be afraid to write up your full argument on a separate document and attach it.

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Saying the Silent Part Out Loud: Aircraft Parts Will Continue to be Subject to Changing Tariff Rules

September 6, 2025 by Leave a comment

The White House has given the industry more guidance on their plans for import tariffs that may be applied to aircraft parts. In an Executive Order published last night, the Administration confirmed that the United States will set aircraft parts duty rates at unique levels for each trading partner.

“The list of imports for which I may be willing to provide a zero percent reciprocal tariff rate is … [description of other products]; aircraft and aircraft parts…. Given the complex, fact-specific, and sensitive nature of negotiations and the national emergency declared in Executive Order 14257, among other relevant considerations, the imports that might receive a reciprocal tariff rate of zero percent may be different for each final agreement between a foreign trading partner and the United States.”

This confirms that the Administration has no intent to honor the Agreement on Trade in Civil Aircraft provisions (including the statutory provisions that implemented that agreement) that provide for duty-free entry of aircraft and aircraft parts. Instead, the Administration expects to set varying tariff levels for imported aircraft parts, based on the country of origin. This can be very complicated to assess for some parts.

For example, an aircraft component that was produced in France might be a product of France when it sold into the aftermarket by the manufacturer. But the substantial transformation doctrine dictates that if the same part was original equipment on a Boeing aircraft produced in the United States, then it became a product of the United States because the fabrication of the complete aircraft (incorporating the component) was a complex assembly. Thus, two otherwise identical aircraft parts might actually be treated differently upon their import into the United States, with the former being a product of France subject to the EU HTSUS provisions, and the latter being a product of the United States that may eligible for duty-free return (assuming that it has not been advanced in value while abroad).

Aviation has a robust record-keeping practice, but the historical duty-free treatment of aircraft parts has meant that the record-keeping practices evolved to support airworthiness, rather than for the purpose of meeting import tariff rules. Modern aircraft parts record-keeping practices may be inadequate in some cases to support common exceptions that should otherwise apply to the U.S. import of aircraft parts.

In June, ASA published an argument to the United States government suggesting that current United States law does not permit duties on aircraft parts, because of (1) the Agreement on Trade in Civil Aircraft and also (2) statutory law that implemented the duty-free treatment of aircraft and aircraft parts. That discussion included the following text:

Any effort to impose tariff-based restrictions on commercial aviation must take into account the
Agreement on Trade in Civil Aircraft. The Agreement on Trade in Civil Aircraft requires
signatories to eliminate tariffs on aircraft and aircraft parts. The Agreement has been signed by
the United States and by many of its major aviation trading partners, including Canada, France,
and the United Kingdom

In 1979, Congress approved the ATCA. That law authorized the president to accept the final
language of the Agreement on Trade in Civil Aircraft and established that it would become
effective when the President finds that other countries have accepted the obligations of the
agreement with respect to the United States. The current implementation of this in the U.S.
Code recognizes that Congress approved the ATCA. While President Carter signed the
Agreement in 1979, it was President Reagan who issued the proclamation described in the
authorizing legislation. At least since 1984, then, the ATCA has been recognized as part of the
law of the United States. The mechanism by which Congress approved the ATCA and
authorized the President to proclaim the ATCA makes it a “congressional-executive agreement.”

Congress has passed other statutory provisions to implement ATCA. For example, the ATCA is
defined in by statute as “the Agreement on Trade in Civil Aircraft approved by the Congress
under section 2503 of [title 19 of the U.S.C.].” Congress has identified that the negotiating
objectives of the United States include eliminating tariff barriers through expanding membership
in the ATCA. General Note 6 of the HTSUS establishes which goods are eligible for duty-free
treatment under the ATCA, and the current language of that General Note was established in
1996 by Congress in the Miscellaneous Trade and Technical Corrections Act of 1996. Thus,
the duty-free treatment of aircraft is established under both the Agreement on Trade in Civil
Aircraft (an international agreement) and also by implementing domestic legislative language.
Eliminating those provisions means eliminating statutory law, as well as eliminating U.S.
obligations under an international agreement. [citations omitted]

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Late Friday Changes to the Tariff Rules – Still No Love for EU Aircraft Parts

August 29, 2025 by Leave a comment

To round out our week, this afternoon the government has issued new tariff rules. Spoiler alert – it extends certain exemptions for products of China, but it does nothing useful for aircraft parts.

Welcome to the world, revision 21 of the 2025 HTSUS!

I’ve been watching the HTSUS carefully because I am expecting to see a change excluding EU aircraft parts from the ‘product-of-the-EU’ tariffs in Chapter 99. That change has not yet been issued. The change was foreshadowed in a White House Statement that was issued a week ago (see our blog post from 8/22). But the 15% duty rate is still (currently) applied to aircraft parts that are products of the EU.

So what did we see in revision 21? Minor changes to the way that we process products of China. The China exceptions for certain goods (covered under HTSUS 9903.88.69 and 9903.88.70, and their cross-referenced subchapter III notes) are extended through November 29, 2025. These are a variety of specific goods that have been excluded from tariffs by order of the U.S. Trade Representative. The list includes certain LCD modules and main board assemblies. Most aircraft parts fall outside of this list of exempted products from China.

Keep your eyes out for 2025 HTSUS revision 22 – if that is issued next week then it might change the treatment of civil aircraft parts that are the product of the European Union.

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New Guidance on Tariffs for Aircraft Parts (Aug. 6, 2025)

August 6, 2025 by Leave a comment

Tariffs continue to be a moving target. Today’s Federal Register includes some new tariff changes that affect aircraft parts imports (some of these new provisions are not yet listed in revision 17 to the HTSUS).

A quick look at some major jurisdictions that produce civil aircraft parts shows the variety of approaches currently being used to assign tariff value to aircraft parts being imported into the United States:

Source (“product of”)Duty and Tariff Code
Aircraft parts that are products of Brazil (e.g. many Embraer parts):Base duty plus 10% additional duty (9903.02.09)(but NOT the additional 40% (9903.01.82)) for aircraft parts)
Aircraft parts that are the products of Canada (e.g. many Bombardier parts):If subject to USMCA – no additional duty (9903.01.14)
If NOT subject to USMCA  – base duty plus 35% (9903.01.10)
Aircraft parts that are products of the EU** (e.g. many Airbus parts):The higher of 15% (9903.02.20) or the normally-applicable base duty value if it exceeds 15% (9903.02.19)
Aircraft parts that are products of Japan (e.g. JAMCO parts):Base duty plus 15% (9903.02.30)
Aircraft parts that are products of the UK (e.g. many BAE Systems parts):No additional duty for aircraft parts (9903.96.01)

This table assumes an aircraft part that is subject to heading 8807 (where the base duty is 0%). In all cases, the civil aircraft-specific provisions are often limited to certain tariff codes, so please confirm the treatment of your actual import based on its tariff classification and actual country of origin. There may be additional codes and duties (or exceptions) that apply to your transaction based on the specific facts of your import.

These rates and applications are constantly changing, so be sure to verify information for the date of your entry into the U.S. Customs Zone!

** SPECIAL NOTE: The EU has reported that the United States has agreed to accept civil aviation products of the EU (including aircraft parts) with no additional duty; however this is not yet reflected in any Executive Order, Federal Register Notice, nor HTSUS provision. Stay tuned – we hope that this exception will be implemented into U.S. trade law, soon!

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Tariff Questions – a Few Common Scenarios

April 18, 2025 by Leave a comment

We have been receiving questions from ASA members about the application of tariffs to various transaction models. Here are a few common scenarios upon which questions have been based. Note that we are using Airbus as our base manufacturer with an assumption that the parts and products in question are products of France (and thus subject to US import rules).

As always, tariffs are changing on a day-to-day basis so make sure you assess the current tariffs as of the date on which the the goods are entered into the United States.

Scenario 1 (“product of”):

An ASA member located in the United States purchase aircraft parts from a company in China. The aircraft parts were all manufactured in France, and are fully products of France. We assume for purposes of this scenario that the aircraft parts are not classified as articles of iron or steel, derivative articles of iron or steel, articles of aluminum, nor derivative articles of aluminum (see our earlier blog article on aluminum and steel). At some point in the past these aircraft parts were legally purchased by the company in China and imported into China (where they are currently located). The parts remain in the new, unused condition (with no material change from their original manufactured condition). The parts have never previously entered the United States. The parts are expected to be shipped from China to the ASA member’s U.S. location on or after April 18, 2025 (today’s date).

Discussion of Scenario 1 (“product of”):

The parts in this scenario are products of France. The fact that they have been warehoused in China does not change this. When imported into the United States, these parts will be identified under the appropriate HTSUS heading (e.g. 8807.xx) and subject to the general rate of duty associated with that heading (which may be a zero-duty heading). Because they are products of France, they will also be subject to the current temporary 10% tariff (HTSUS 9903.01.25) on imported goods “of any country.” There is currently no aviation exemption that would generally exclude this 10% tariff for aircraft parts.

The additional tariff on products of the EU is currently suspended. When (or if) the suspension terminates, products of the EU may revert to the 20% duty (HTSUS 9903.01.50).

Scenario 2 Complex Assembly

An aircraft parts was made in the United States (in the past). It was exported to France where it was installed as part of the assembly of a new Airbus aircraft. Does this make the aircraft a product of the United States or a product of France?

Discussion of Scenario 2 Complex Assembly

The manufacture of a complete aircraft is a complex assembly that represents a transformative process. The aircraft will become a product of France, even though its parts may have come from other locations. Each of the parts that make up the aircraft will become a product of France.

Note that the new temporary tariffs include a provision for substantial US value in a foreign product. If the U.S. content of a non-U.S. product provides at least 20 percent of the Customs value of the imported product, then the U.S. content value may be imported under HTSUS 9903.01.34 without being marked up by the temporary 10% tariff found in HTSUS 9903.01.25. The remaining non-U.S. content value remains subject to the temporary 10% tariff found in HTSUS 9903.01.25 unless some other exception applies. The term “U.S. content” refers to the value of an article attributable to the components wholly obtained, produced entirely, or substantially transformed in the United States.

Scenario 3 (Disassembly)

An ASA member purchases an Airbus aircraft that is entirely a product of France. The aircraft is currently located in the United Kingdom The ASA member causes the aircraft to be disassembled in the United Kingdom. The removed parts are then imported into the United States. What is the country of origin for these removed aircraft parts? What if there is an aircraft part that is removed and that particular part has a “made-in-the USA” dataplate on it?

Discussion of Scenario 3 (Disassembly)

While complex assembly is a transformative process, disassembly is not a transformative process. Consequently, the disassembly of the aircraft in the United Kingdom does not transform the removed parts into products of the United Kingdom. It also does not allow the parts to convert to products of any other nation. The assembly made the parts products of France and they remain products of France after they have been dissembled.

The unit that bears a “made-in-the USA” dataplate was transformed into a product of France when it was part of the complex assembly into an aircraft. Disassembly is not a transformative process so it does not restore a prior condition. The part remains a product of France (based on the earlier transformative process) even though it has a made-in-the-USA dataplate.

It is interesting to note that disassembly was considered to be production (a potentially transformative process) under NAFTA (see e.g. 19 C.F.R. 181.132), but not under the USMCA (see HQ 342177). The USMCA permits such goods to be treated as recovered material that can be formed into a remanufactured good under the right facts (e.g. 19 C.F.R. Part 182 Appendix A Section 4). Neither of these treaties is applicable to the problem as stated, however, because the disassembly in our scenario takes place outside of the U.S., Mexico or Canada.

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Tariff Update

February 24, 2025 by 2 Comments

We’ve been answering a number of questions from our members about tariff status. This article is meant to summarize what we know about recent tariff activity, but the administration hasn’t maintained a uniform message about tariffs, so what we know could change at any time.

UPDATE: We have published more up-to-date information for products of Canada, Mexico and other Non-US sources and for steel and aluminum.

China

The United States has applied a 10% tariff in addition to any pre-existing tariffs that already applied to aircraft parts from China.

It is important to recognize that there is an existing list of products of China that were already subject to a 25% ‘additional duty’ provision. This is described under subheading 9903.88.01 and the description can be found under U.S. note 20(b) to sub-chapter III of chapter 99 of the US Harmonized Tariff System. Many aircraft parts are subject to a 25% duty under this provision, including those under (for example) headings 8409, 8411, and 8807. This means that the additional 10% duty of tariff 9903.01.20 brings the import duty on those aircraft parts to 35% (assuming they would have been otherwise subject to a zero-duty entry, but-for the ‘additional duty’ provisions, e.g. aircraft parts under headings 8409, 8411, or 8807).

Because of the peculiar way that the China tariffs had been drafted, it is possible that articles subject to a non-zero base duty may have that base duty doubled (see this article for a detailed explanation). This is a non-issue for most aircraft parts because most are subject to a zero percent base duty rate, but some aircraft parts (like certain fasteners) have a non-zero base duty and the peculiarities will need to be resolved for those imports.

Canada and Mexico

The United States is scheduled to impose 25% tariffs against substantially all products of Canada and substantially all products of Mexico. In each case the tariffs are currently schedule to apply to Canadian imports and Mexican imports as of 12:01 am March 4, 2025. The tariffs (which are the description of how the duty rates will be applied) were withdrawn when the Canada and Mexico tariffs were delayed, so the republished tariffs could change.

Typically, the 25% tariff would be applied to the import value of the goods (25% of the value is charged as a duty). When the goods are exported from the United States for the purpose of obtaining repair abroad, and then subsequently returned to the U.S., the dutiable value upon return is typically calculated based on the parts-and-labor-cost of the MRO work that was accomplished abroad (unless it is a no-charge repair, like a warranty repair, in which case it is based on the fair market value of the repair). This is covered under chapter 98 tariff subheadings like 9802.00.40 (for warranty repairs) or 9802.00.50 (for non-warranty repairs). The goods would be subject to a basic duty based on the repair value times the rate that applies to the underlying good. For example, if the repair cost was $20,000 and the underlying aircraft part was subject to heading 8807, then the old rate of duty would be zero percent so the duty would be zero dollars. Under the new tariffs with the 25% duty rates, though, if the repair cost was $20,000 and the tariff on products of the country in which the repair was performed is at a 25% duty rate, then the U.S. importer to whom the repaired part is returned (from Canada) would need to pay an import duty of $5,000 (in addition to the repair cost).

Steel and Aluminum

The Administration has also issued orders to apply and increase duty rates on steel and aluminum (including plates, sheets, strips, bars, rods, tubes and wires). The new duty rates for aluminum from most countries will be 25% (in addition to any other applicable tariffs). Derivative products made from aluminum or steel will also be subject to a 10% duty (in addition to any other applicable tariffs). The executive order that announced these is quite complicated, with different phase-in dates for different countries, and some higher duty rates for certain countries (for example Turkey will face a 50% duty rate on all steel articles imports and Russia will face a 200% duty rate on imported derivative aluminum articles).

If you think that the steel or aluminum tariffs may apply to your imports then please be sure to read the tariffs thoroughly (don’t just rely on this blog article because there are too many details to republish them all here).

Other Targets

In tomorrow’s Federal Register, we expect to see a new request from the U.S. Trade Representative (USTR). The new request will ask the American people to identify any unfair trade practices by other countries, with a discussion of the harm to the United States. The draft publication refers to these as non-reciprocal trade arrangements so it appears that the Administration (which has threatened to implement reciprocal tariffs) may be looking at such arrangements as justifications for tariffs on comparable products from these source countries. This investigation is a response to the “America First Trade Policy” Executive Order.

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