Application Acceptance System Overview
The US Department of Commerce Bureau of Industry and Security (BIS) announced on September 15 the commencement of application acceptance for additional product categories subject to 50% additional tariffs on steel and aluminum products under Section 232 of the Trade Expansion Act of 1962. Following formal notification in the Federal Register on September 17, the application acceptance period runs from September 15-29, marking the second implementation following May 2025.
Derivative Product Application Process Mechanism
Three Annual Acceptance Periods: BIS established a new process in May to add "derivative products" containing steel and aluminum to Section 232 tariff coverage, introducing a system that accepts addition applications from US manufacturers and industry associations via email three times annually (January, May, September), with each period lasting two weeks.
Review and Decision Procedures: The system works by BIS publishing application contents excluding confidential information after receiving applications, accepting public comments on the federal government website for 14 days, then determining within 60 days whether to add items to coverage.
Previous Process Results and Impact
Approximately 400 Items Added: In the previous May addition process, BIS added approximately 400 derivative product items to Section 232 tariff coverage in August. According to US think tank Cato Institute, added items included "whipped cream, air fresheners, silverware, buckets, office furniture, lawn mowers, baby strollers, fire extinguishers," expanding coverage to a wide range of products using steel or aluminum in frames or containers.
Future Outlook
Trade attorneys in Washington DC indicate that, given the precedent of many items being added to Section 232 tariff coverage in the previous addition process, companies seeking domestic industry protection are expected to submit applications this round as well, with BIS likely to further expand coverage. US Customs and Border Protection (CBP) guidance dated August 15 clearly identifies items displayed in bold as newly added to coverage in August 2025.