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9903.85.07 Explained: Section 232 Derivative Aluminum Products

Published: October 3, 2026  ·  8 min read
9903.85.07 Explained: Section 232 Derivative Aluminum Products
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Key Points

On this page

  1. What 9903.85.07 is and what program created it
  2. Affected products and HTS coverage
  3. Country exclusions and effective date windows
  4. How 9903.85.07 stacks with other duties
  5. The April 2026 consolidated cutover
  6. What importers should do
  7. Key references

HTS code 9903.85.07 is the Section 232 Chapter 99 overlay code for derivative aluminum products described in subdivision (j) of note 19 to subchapter III of Chapter 99. As of October 3, 2026, the code's effective windows have all closed at the April 6, 2026 consolidated Section 232 cutover. Importers and brokers researching this code are most likely reviewing past entries or auditing duty liability from the period spanning 2025-03-12 through 2026-04-06. The links in this article go to the primary documents: the official HTSUS schedule, CBP guidance pages, and the Federal Register itself. Read the source.

What 9903.85.07 is and what program created it

Section 232 of the Trade Expansion Act authorizes the President to impose duties on imports that threaten national security. The aluminum Section 232 action originally targeted primary aluminum products, but was later extended to derivative aluminum products, meaning manufactured articles that contain aluminum as a significant component even if they are not raw aluminum.

9903.85.07 is the specific Chapter 99 subheading that carried the Section 232 duty for derivative aluminum products during the BIS inclusions process, as defined by subdivision (j) of note 19 to the HTSUS subchapter. The official heading text describes it as covering derivative aluminum products provided for in that subdivision, with the notation that it was superseded at the consolidated Section 232 cutover on 2026-04-06.

Like all Chapter 99 Section 232 codes, 9903.85.07 does not stand alone on a customs entry. It rides alongside the regular chapter 1-97 classification line for the underlying product. Both lines must appear on the entry summary for CBP to assess the additional duty correctly. Confirm exact entry instructions with CBP or in current ACE filing guidance.

For more background on how Section 232 duties interact with other trade remedy programs, see our article How Do Section 232, Section 301 and AD/CVD Duties Stack?

Affected products and HTS coverage

The heading covers derivative aluminum products whose specific chapter 1-97 subheadings are listed in subdivision (j) of note 19. The facts block contains 40 of the 52 total scope rules for this heading. The examples below are a representative sample. The heading covers more lines than this article lists. Importers must consult subdivision (j) of note 19 in the official HTSUS at hts.usitc.gov for the complete enumeration.

Representative subheadings covered

The following subheadings appear among the scope rules in the facts block. Each entry reflects the applicable country-exclusion and date window described in the next section:

Again, these are examples drawn from the first 40 of 52 rules. Do not treat this list as exhaustive. Verify coverage for any specific subheading against the full note 19(j) text in the HTSUS.

Country exclusions and effective date windows

9903.85.07 used a country-exclusion model: a subheading is in scope for all countries except those listed as excluded for that subheading and window. Goods from excluded countries were not subject to the Section 232 derivative aluminum duty under this code during the specified window. The exclusions and windows changed over time as additional subheadings and countries were added through the BIS inclusions process.

Window 1: 2025-03-12 through 2025-06-04

During this first window, a set of subheadings entered scope with Russia (RU) excluded. These included 7610.10.00, 7610.90.00, 7614.10.50, 7614.90.20, 7614.90.40, 7614.90.50, and numerous 7615.10.xx lines (7615102015, 7615102025, 7615103015, 7615103025, 7615105020, and others). Goods from Russia in these subheadings were not subject to the 9903.85.07 duty in this window; goods from all other origins were.

Window 2: 2025-04-04 through 2025-06-04

Subheading 7612.90.10 entered scope during this overlapping window with no country exclusions stated for this particular rule, meaning all origins were covered for that subheading from 2025-04-04 through 2025-06-04.

Window 3: 2025-06-04 through 2026-04-06

The largest group of subheadings came into scope from 2025-06-04 onward, excluding both Great Britain (GB) and Russia (RU). This group included 7610.10.00, 7610.90.00, 7614.10.50, 7614.90.20, 7614.90.40, 7614.90.50, all the 7615.10.xx series lines, 7615.20.0000, 7616.10.9090, 7616.99.10xx, 7616.99.51xx lines, and 7612.90.10 (now with GB added as an excluded country).

Window 4: 2025-08-18 through 2026-04-06

A final group of subheadings entered scope from 2025-08-18, excluding only Great Britain (GB). This group included 7612.10.0000, 7612.90.5000, 7613.00.0000, and 7614.10.10. Goods from GB in those subheadings were excluded; all other origins were in scope.

All windows closed at 2026-04-06. Entries liquidated or reliquidated for this period should reflect the correct window and country-exclusion rules. For guidance on the liquidation clock and correction procedures, see Customs Entry Liquidation: The One-Year Clock, Extensions, and Notices.

How 9903.85.07 stacks with other duties

Section 232 duties are cumulative with most other trade remedy duties unless a specific provision says otherwise. That means an aluminum derivative product from a country subject to antidumping or countervailing duty orders, or to Section 301 tariffs, would owe all applicable duties simultaneously. The 9903.85.07 line on the entry adds its Section 232 rate on top of whatever the chapter 1-97 column 1 general rate is, plus any applicable AD/CVD cash deposit.

The specific rate of duty applicable under 9903.85.07 is not stated in the facts block. Confirm the applicable rate with the note 19 text in the HTSUS or with your broker. For a broader discussion of how these programs layer, see How Do Section 232, Section 301 and AD/CVD Duties Stack?

Goods from GB and RU were excluded from this code's scope during the periods noted above. That means the Section 232 derivative aluminum duty under 9903.85.07 did not apply to those origins for those subheadings during those windows. Verify whether any successor code applies to those origins after 2026-04-06 by consulting the current HTSUS and your broker.

The April 2026 consolidated cutover

The official heading text states that 9903.85.07 was "superseded at consolidated-232 cutover 2026-04-06." This means that as of 2026-04-06, this specific BIS-inclusions code no longer governs new entries. Importers filing entries for goods entering on or after 2026-04-06 must use the successor code or codes applicable under the consolidated Section 232 framework.

Importers with entries filed between 2025-03-12 and 2026-04-06 for in-scope subheadings from non-excluded countries should confirm that 9903.85.07 was reported correctly on those entries and that duty was assessed at the correct rate for the correct window. Entries filed incorrectly may be subject to additional duties, penalties, or the need for a post-entry correction. Confirm proper correction procedures with CBP.

For a full overview of 2026 tariff code changes and the consolidated Section 232 framework, see our 2026 tariff code overview.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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