9903.81.90 (Ended): Section 232 Steel Derivative Full-Value Duty
Key Points
- HTS 9903.81.90 imposed a 50 percent additional duty on derivative iron and steel products enumerated in subdivision (m) of Note 16 to Chapter 99, calculated on the full value of the goods.
- The heading was terminated on April 6, 2026, when Proclamation 11021 (91 FR 18201) consolidated the Section 232 metal actions into the 9903.82 heading series.
- The duty did not disappear on April 6, 2026; entries filed on or after that date instead report the applicable consolidated 9903.82 heading.
- Great Britain (GB) was excluded from coverage for all subheadings that applied under this heading during its effective window.
- Section 232 duties are not eligible for drawback; an importer who overpaid under this heading follows the ordinary post summary correction or protest path.
On this page
- What 9903.81.90 covered and the program that created it
- The 50 percent rate and its effective window
- Product scope, sibling headings, and country exclusions
- How the heading appeared on an entry
- The April 6, 2026 consolidation and what replaced this heading
- Correction and refund position for past entries
- What importers should do
- Key references
HTS 9903.81.90 was a Chapter 99 overlay heading that imposed a 50 percent additional Section 232 duty on derivative iron and steel products, assessed on the full value of the merchandise. As of October 17, 2026, this heading is no longer in force. It was terminated on April 6, 2026, when Proclamation 11021 consolidated the Section 232 metal actions into a new 9903.82 heading series. The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source.
What 9903.81.90 covered and the program that created it
Heading 9903.81.90 was part of the Section 232 Steel Derivatives program, which extended national-security-based steel tariffs beyond primary steel mill products to downstream, or "derivative," articles whose value depended substantially on iron or steel inputs. The official heading text read:
Except as provided in heading 9903.81.92, derivative iron or steel products provided for in the tariff subheadings enumerated in subdivision (m) of note 16 to this subchapter.
The product universe was defined by subdivision (m) of Note 16 to Chapter 99 of the Harmonized Tariff Schedule. That note enumerated hundreds of chapter 1-97 subheadings covering a wide range of fabricated iron and steel goods, including pipe fittings, structural shapes, containers, wire products, and structural assemblies, among many others.
The 50 percent rate and its effective window
While in force, heading 9903.81.90 carried an additional duty rate of 50 percent of the full entered value of the covered derivative product. This was the full-value basis: unlike its sibling heading 9903.81.91, which calculated duty only on the steel content of the article, 9903.81.90 applied the 50 percent rate to the total value of the good. The heading operated under the legal authority of the Section 232 national security provisions and, ultimately, was terminated by Proclamation 11021 (91 FR 18201) on April 6, 2026.
For the specific subheadings covered in the facts available as of October 17, 2026, most carried effective windows running from either June 4, 2025, or August 18, 2025, through the termination date of April 6, 2026. Confirm the precise window for any individual subheading in the current HTSUS or historical schedule, or with a licensed customs broker.
Product scope, sibling headings, and country exclusions
Sibling headings
Heading 9903.81.90 operated alongside two closely related headings that together formed the Section 232 steel derivatives framework:
- 9903.81.91: applied the Section 232 duty on the steel-content basis rather than the full value of the article.
- 9903.81.92: was the no-duty branch, covering derivative steel products that were expressly excluded from the additional duty, such as those subject to an approved exclusion or a country-level exemption.
Because the heading text of 9903.81.90 opened with "Except as provided in heading 9903.81.92," any entry that qualified for the 9903.81.92 exception fell out of the 9903.81.90 duty entirely.
Country exclusions
Great Britain (GB) was excluded from coverage for every subheading that fell under 9903.81.90 during its effective window. Imports originating in GB did not attract the 50 percent duty under this heading for the periods covered by the available rules. All other countries of origin, unless separately exempted by another provision, were subject to the duty.
Covered subheadings
The 334 subheading-and-country rules that were in force under 9903.81.90 all ended by April 6, 2026, and none remain active. The covered subheadings spanned a broad range of iron and steel derivatives, including, among others, items classifiable under subheadings in the 7302, 7307, 7308, 7309, 7310, 7311, 7312, and 7216 series. To identify whether a specific subheading was in scope during a past import, consult the historical HTSUS or CBP guidance for that entry date.
How the heading appeared on an entry
Like all Chapter 99 overlay codes, 9903.81.90 was not a standalone classification. It rode alongside the regular chapter 1-97 classification line on the entry summary. An entry for, say, steel pipe fittings would carry the substantive HTS subheading from chapter 73 on one line and 9903.81.90 on a second line to trigger the additional 50 percent duty. Customs brokers entered both codes in ACE, and CBP collected the additional duty at the 9903.81.90 rate on top of any general column 1 or other applicable duties. The 9903.81.90 line itself carried no separate merchandise description; it functioned as a duty-rate modifier.
The April 6, 2026 consolidation and what replaced this heading
Proclamation 11021, published at 91 FR 18201, consolidated the Section 232 metal actions into a new 9903.82 heading series, effective April 6, 2026. CSMS message 68253075 provided operational CBP guidance on the transition. From April 6, 2026 onward, importers filing entries for derivative iron and steel products that would previously have required 9903.81.90 instead reported the applicable heading in the 9903.82 series. The duty obligation did not end; it migrated to the consolidated framework. Importers and brokers should verify the correct current heading in the HTSUS or check with a broker, because this article does not carry a specific 9903.82 successor heading number for every product line.
For a broader overview of how the 2026 tariff code changes affect entries, see the 2026 tariff code overview.
Correction and refund position for past entries
The termination of heading 9903.81.90 on April 6, 2026, did not by itself generate a refund entitlement. The Section 232 duty moved to the consolidated 9903.82 headings rather than being eliminated, so there was no overpayment arising from the consolidation alone.
An importer who believes it overpaid under 9903.81.90 during the heading's active window, for example because goods were misclassified as subject to 9903.81.90 when they should have been under the no-duty heading 9903.81.92, may seek correction through the ordinary post summary correction or protest path for that entry. The IEEPA refund process does not apply to Section 232 duty. Additionally, Section 232 duties are not eligible for drawback. Importers evaluating whether a past entry was correctly assessed should consult the entry record and, where a filing error is suspected, consider a post-entry audit of affected entries.
What importers should do
- If you filed entries under 9903.81.90 during its active window and believe an error occurred, pull the affected entry summaries and evaluate whether a post summary correction or protest is warranted under the ordinary CBP process.
- For entries filed on or after April 6, 2026, do not report 9903.81.90; identify and report the applicable heading in the consolidated 9903.82 series as directed by CSMS 68253075 and the current HTSUS.
- Confirm that your customs broker's tariff software has removed 9903.81.90 from its active code set and is applying the correct 9903.82 heading for current derivative iron and steel imports.
- Remember that Section 232 duties paid under this heading are not recoverable through the drawback program, so do not include them in any drawback claim calculations.
Key references
- Proclamation 11021, 91 FR 18201: the proclamation that consolidated Section 232 metal actions into the 9903.82 headings and terminated 9903.81.90 effective April 6, 2026.
- CBP CSMS 68253075: CBP operational guidance on the Section 232 consolidation transition.
- Harmonized Tariff Schedule of the United States (HTSUS): official schedule including Chapter 99 and Note 16, subdivision (m).
- U.S. Customs and Border Protection (CBP): entry filing, post summary corrections, and protest procedures.
- 9903.81.91 (Ended): Section 232 Steel Derivative Duty on Steel Content: sibling heading that applied the duty on the steel-content basis.
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