9903.81.91 (Ended): Section 232 Steel Derivative Duty on Steel Content

Key Points

• HTS 9903.81.91 ended on April 6, 2026, when Proclamation 11021 (91 FR 18201) consolidated the Section 232 metal actions into the 9903.82 heading series.
• While it applied, the heading imposed the duty of the applicable base subheading plus a duty of 50% upon the value of the steel content of qualifying derivative iron or steel products.
• All 423 product-country rules under this heading ran from August 18, 2025 through April 6, 2026, and excluded Great Britain from coverage; none remain in force as of the as-of date of this article (October 16, 2026).
• The duty did not disappear on April 6, 2026; it moved. Entries on or after that date used the consolidated 9903.82 headings instead.
• The end of this heading created no automatic refund; an importer who overpaid follows the ordinary post summary correction or protest path, and Section 232 duties are not eligible for drawback.

On this page

1. What heading 9903.81.91 covered
2. How the duty was calculated: the steel-content basis
3. Sibling headings and the Chapter 99 structure
4. Product and country scope while the heading applied
5. How the heading appeared on a customs entry
6. The April 6, 2026 consolidation and what replaced 9903.81.91
7. Refund and correction posture for past entries
8. What importers should do
9. Key references

HTS 9903.81.91 was a Chapter 99 overlay heading used to collect Section 232 steel derivative duties on a steel-content-value basis. It applied to derivative iron or steel products covered by the tariff subheadings listed in subdivision (n) of note 16 to Subchapter III of Chapter 99, for shipments from countries other than Great Britain, between August 18, 2025 and April 6, 2026. On April 6, 2026, Proclamation 11021 ended the heading by folding the Section 232 metal actions into a consolidated 9903.82 heading series. Importers and brokers reviewing past entries filed under this code should treat it as a closed chapter.

The links in this article go to the primary documents: the proclamation, the Federal Register notice, CBP guidance, and the official tariff schedule pages themselves. Read the source.

What heading 9903.81.91 covered

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 (n) of note 16 to this subchapter."

In plain English, the heading applied to finished and semi-finished goods that were not themselves primary steel or iron articles but that contained meaningful steel content, specifically those HTS subheadings that the note 16(n) list named. The universe of eligible subheadings was large: the facts block confirms 423 product-country rules were tied to this heading while it was live, spanning chemicals, paints, cosmetics, petroleum products, and other goods whose packaging or components included steel.

The heading operated as part of the Section 232 Steel Derivatives program, the authority under which the United States extended national-security-based trade measures beyond primary steel mill products to downstream goods that incorporate steel.

How the duty was calculated: the steel-content basis

The rate under 9903.81.91 was the duty provided in the applicable base subheading plus a duty of 50% upon the value of the steel content. That second element, the 50% levy on steel-content value, was the defining feature of this heading and distinguished it from its sibling 9903.81.90.

Importers were responsible for determining and declaring the value of the steel content within the imported article. The 50% rate applied to that steel-content value, not to the full customs value of the goods. Accurate steel-content valuation was therefore a compliance obligation on every qualifying entry.

Confirm the precise methodology for steel-content valuation in the current Harmonized Tariff Schedule at hts.usitc.gov or with your broker, because the facts block does not carry additional detail on the valuation methodology beyond the rate itself.

Sibling headings and the Chapter 99 structure

Heading 9903.81.91 did not stand alone. It was part of a trio of Section 232 steel derivative headings that operated alongside each other:

• 9903.81.90 covered derivative iron or steel products on a full-value basis, meaning the Section 232 duty was calculated on the entire customs value of the article rather than just its steel content.
• 9903.81.91 (this heading) covered the same category of derivative products but imposed the 50% duty only upon the value of the steel content, making it the steel-content-value branch.
• 9903.81.92 was the no-duty branch. The heading text of 9903.81.91 explicitly carved out goods "as provided in heading 9903.81.92," meaning products that qualified for an exclusion or exemption were directed away from 9903.81.91 entirely.

Which of the three headings applied to a given shipment depended on the product, the country of origin, and whether any exclusion had been granted. All three headings were ended by the same April 6, 2026 consolidation event.

Product and country scope while the heading applied

While 9903.81.91 was in force, its 423 product-country rules all shared the same effective window: August 18, 2025 through April 6, 2026. Every rule excluded Great Britain from coverage, meaning imports of the listed subheadings from Great Britain were not subject to 9903.81.91 during that period.

The subheadings spanned a wide range of HTS chapters, including dairy preparations, petroleum products, halogenated hydrocarbons, pharmaceutical goods, paints and varnishes, perfumes and cosmetics, and soaps, among others. The first 40 of the 423 rules appear in the facts record, with the balance confirmed in the note 16(n) list in the official tariff schedule. Verify the complete list at hts.usitc.gov.

As of October 16, 2026, zero of the 423 rules remain in force. All ended on April 6, 2026.

How the heading appeared on a customs entry

Like all Chapter 99 codes, 9903.81.91 was a secondary overlay line. It did not replace the base classification in Chapters 1 through 97. An importer filed two lines on the entry summary:

• The primary HTS subheading from Chapters 1 through 97, which captured the base duty rate and the commodity description.
• The Chapter 99 code 9903.81.91 as an additional line, which triggered the Section 232 steel derivative duty of 50% on the declared steel-content value.

Both lines were required for a compliant entry while the heading was active. The CBP guidance published as CSMS 68253075 addressed the consolidation and the filing requirements for entries on or after April 6, 2026.

The April 6, 2026 consolidation and what replaced 9903.81.91

Proclamation 11021, published at 91 FR 18201, ended heading 9903.81.91 on April 6, 2026 by consolidating the Section 232 metal actions into the 9903.82 heading series. The consolidation covered both the steel and the aluminum derivative programs alongside the primary metal actions.

The duty did not disappear. Importers whose goods were in transit or whose entries were filed on or after April 6, 2026 were required to use the consolidated 9903.82 headings instead of 9903.81.91. The facts block does not identify a specific successor heading within the 9903.82 series for this exact product scope, so importers should confirm the correct 9903.82 heading with their broker or in the current tariff schedule at hts.usitc.gov.

For broader context on the 2026 tariff code changes, see the 2026 tariff code overview. For the Section 232 auto parts extension, which followed a parallel structure, see the article on 9903.94.05: Section 232 Auto Parts Tariff Rate, Scope, and Stacking.

Refund and correction posture for past entries

The end of heading 9903.81.91 did not itself generate a refund entitlement. Because the Section 232 duty moved to the consolidated 9903.82 headings rather than ending, there was no overpayment created simply by the heading's termination.

If an importer believes it overpaid under 9903.81.91 for a different reason, such as a classification error or an incorrect steel-content valuation, the path is the ordinary post summary correction or protest process for that entry. The IEEPA refund process does not apply to Section 232 duties.

Additionally, Section 232 duties are not eligible for drawback. An importer cannot recover Section 232 steel derivative duties paid under 9903.81.91 through a drawback claim, regardless of the disposition of the imported goods after entry.

Confirm the specific procedural steps for post summary corrections and protests with your broker or at cbp.gov. For a related look at post-entry review, the article Hire a Trade Consultant or Use CustomsGenius for Post-Entry Review? covers the general workflow.

What importers should do

• Review any open or unliquidated entries filed between August 18, 2025 and April 6, 2026 to confirm that 9903.81.91 was applied correctly and that the steel-content value declared on each entry was accurate.
• For entries filed on or after April 6, 2026, verify that the correct consolidated 9903.82 heading was used and that 9903.81.91 does not appear on those entry summaries.
• If a correction is needed for a past entry, pursue the ordinary post summary correction or protest path; do not file a drawback claim, as Section 232 duties are not drawback-eligible.
• Confirm the complete note 16(n) subheading list and the applicable 9903.82 successor heading in the current Harmonized Tariff Schedule at hts.usitc.gov or through your licensed customs broker.

Key references

• Proclamation 11021, 91 FR 18201 - the proclamation that consolidated the Section 232 metal actions into the 9903.82 series and ended heading 9903.81.91 on April 6, 2026.
• CBP.gov - CSMS 68253075 and related guidance on the April 6, 2026 Section 232 consolidation and entry-filing requirements.
• Harmonized Tariff Schedule, hts.usitc.gov - the official schedule, including the full note 16(n) subheading list that defined the product scope of 9903.81.91 and the current 9903.82 consolidated headings.
• Federal Register, federalregister.gov - Federal Register notices related to the Section 232 Steel Derivatives program.