Is your import at risk?

Jason Dickstein, president of the Washington Aviation Group, offers some insight on how to navigate the new US tariffs on aluminium and steel.

This article is adapted from a shorter version which was published in MRO Management magazine April 2025 and includes full lists that were not included in the magazine version.

The United States tariff rules are changing so quickly that is it is very difficult for businesses to assess what their obligations are, or will be, when they import aircraft parts into the US.

This article is meant to serve as a resource for US importers to bear their analysis of import duty obligations. The tariff rules are changing very rapidly, and this article is based on revision 5 of the 2025 HTSUS; so, what you read here should be used as a starting point only – all determinations should be checked against the current regulations.

Many people have been asking about how the new aluminium, iron, and steel tariffs apply to imported aircraft parts. The answer is that it depends on the base tariff heading/subheading that applies to the imported goods.

For example, if you are importing steel track bolts with shanks or threads that have a diameter of 6mm or more, then these bolts are likely to be subject to classified under subheading 7318.15.20. This tariff code is subject to the additional 25% duty on steel derivative products. Some other bolts may be excluded from the additional 25% duty if their subheading and statistical reporting number fall outside of the (complicated) scope of the tariff.

The first step is to identify the applicable tariff heading and/or subheading (and statistical reporting number). The next step is to identify the appropriate additional tariff and assess whether it applies to your particular subheading.

A 25% duty applies to many raw materials of aluminium, iron, and steel in the following forms (for clarity, codes starting with ‘72’ or ‘73’ are iron and/or steel and codes starting with ‘76’ are aluminium):

• Unwrought aluminium in HTSUS heading 7601;
• Flat-rolled iron or steel products in HTSUS headings 7208, 7209, 7210, 7211, 7212, 7225 or 7226
• Aluminium, iron or steel bars and rods in HTSUS headings 7213, 7214, 7215, 7227, 7228, or 7604
• Iron or steel angles, shapes and sections of 7216 (except subheadings 7216.61.00, 7216.69.00 or 7216.91.00)
• Aluminium, iron or steel wire in HTSUS headings 7217, 7229 or 7605
• Iron or steel sheet piling in HTSUS subheading 7301.10.00
• Iron or steel rails in HTSUS subheading 7302.10
• Iron or steel fish-plates and sole plates in HTSUS subheading 7302.40.00
• Products of iron or steel in HTSUS subheading 7302.90.00
• Aluminium, iron or steel tubes, pipes and hollow profiles in HTSUS heading 7304, 7305, 7306, 7608, or 7609
• Iron and steel ingots, other primary forms and semifinished products in HTSUS headings 7206, 7207 or 7224
• Products of stainless steel in HTSUS headings 7218, 7219, 7220, 7221, 7222 or 7223
• Aluminium plates, sheets and strip in HTSUS 7606
• Aluminium foil in HTSUS 7607
• Castings and forgings of aluminium provided for in subheading 7616.99.51.

If you are importing one of these raw materials, then you will typically declare the imported goods under tariff heading 9903.81.87 (iron or steel) or 9903.85.02 (aluminium), and you will need to pay 25% of the value of the import as an additional import duty.

When the metal has been formed into a useful product of another form, it is considered a derivative product. Derivative products made of iron or steel are subject to a different set of tariff headings: 9903.81.89, 9903.81.90, or 9903.81.91. Derivative products made of aluminium are subject to tariff headings: 9903.85.04, 9903.85.07 and 9903.85.08. These headings each impose a 25% tariff on the articles within their scope.

It is important to recognise that the scope is bounded by the HTSUS codes, and it may exclude certain products made from aluminium, iron or steel. In other words, you might have a good made from aluminium, iron or steel, but that good might NOT be subject to the additional 25% duty. Some tables in this article will help you better assess whether your import might be subject to such an additional duty.

In addition, this 25% additional duty may not apply to derivative iron or steel products (even if they were made from processes outside the US), where the derivative product was processed from steel that was melted and poured in the US (this is another special, detailed rule).

There are two major categories of iron and steel items that are subject to the 25% tariff on derivative products. The first category is a list of articles classified under HTSUS Chapter 72 or 73 (articles of iron and steel). These are articles that include hardware that may be used by a repair station, as well as certain interior and galley parts.

The second is a shorter list of articles classified under chapters 84, 85 and 94. There are similar lists for aluminium articles. While most of the list items appear – at first blush – to be outside of the scope of things typically imported by the aviation maintenance community, any of these articles could find themselves being used in certain installations (including, for example, installations of custom aircraft interiors). For the sake of completeness, included are the entire lists (as they currently stand at the time of writing this article) even though some articles are clearly outside the normal scope of aviation (for example, bulldozer parts are unlikely to be installed in aircraft).

The 25% duty on derivatives applies to the following aluminium, iron and steel categories.  These category listings are offered to help guide importers and are only a summary of the listings. Repair stations may find themselves handling a wide variety of parts, especially when installing interiors, so any of these categories could become relevant. In all cases, check the specific HTSUS code against the rules to make sure your specific product is covered, because some products in each of the categories may not be covered.

List One of HTSUS subheadings and goods subject to the 25% tariff on derivative products of iron and steel subject to heading 9903.81.90 (chapter 73 references) and derivative products of aluminium subject to heading 9903.85.07 (chapter 76 references):

• Sheet pilings (HTSUS 7301)
• Railway track material (HTSUS 7302)
• Certain tube or pipe fittings (HTSUS 7307)
• Certain structures (like buildings and bridges and their parts (HTSUS 7308, 7610)
• Reservoirs, tanks and vats (HTSUS 7309)
• Tanks, casks, drums, cans, boxes and similar containers (HTSUS 7310)
• Containers for compressed or liquefied gas (HTSUS 7311)
• Stranded wire, ropes, cables, plaited bands, and slings (HTSUS 7312)
• Barbed wire (HTSUS 7313)
• Cloth (including endless bands), grill, netting and fencing (HTSUS 7314)
• Chain and parts thereof (HTSUS 7315)
• Anchors and grapnels (HTSUS 7316)
• Nails, tacks, pins, and staples (HTSUS 7317) [for these, US-poured steel may not reflect an exception]
• Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, and washers (HTSUS 7318, 7616 [limited applicability])
• Sewing needles, knitting needles, bodkins, crochet hooks, and embroidery stilettos (HTSUS 7319)
• Springs and leaves for springs (HTSUS 7320)
• Stoves and other cooking appliances (HTSUS 7321)
• Radiators (HTSUS 7322)
• Kitchen and household articles (HTSUS 7323, 7615)
• Sinks and baths (HTSUS 7324)
• Luggage frames (HTSUS 7616.99.1000)
• Ladders (HTSUS 7616.99.5130)
• Venetian blinds (HTSUS 7616.99.5140)
• ‘Other’ cast articles (HTSUS 7325)
• ‘Other’ articles (HTSUS 7326, 7616.99.5190).

List Two of HTSUS subheadings and goods subject to the 25% tariff on derivative products of iron and steel (subject to heading 9903.81.91):

• 8431.31.00 certain passenger or freight elevator parts
• 8431.42.00 Bulldozer or angledozer blades
• 8431.49.10 Parts of ships’ derricks or cranes
• 8431.49.90 Parts of equipment like bulldozers and road rollers
• 8432.10.00 Plows
• 8432.90.00 Parts for agricultural equipment
• 8547.90.00 Insulating fittings
• 9403.20.00 Metal furniture (other than office furniture)
• 9405.99.20 Lighting fittings of brass
• 9405.99.40 Lighting fittings made from things other than brass
• 9406.20.00 Prefabricated building modules made from steel
• 9406.90.01 Prefabricated building modules made from things other than wood or steel.

List Three of HTSUS subheadings and goods subject to the 25% tariff on derivative products of aluminium (subject to heading 9903.85.08):

• 6603.90.8100 Certain umbrella parts
• 8302.10 Certain base metal mountings
• 8302.20 Castors
• 8302.30 Certain other mountings
• 8302.41 Certain base metal mountings suitable for buildings
• 8302.42 Certain base metal mountings suitable for furniture
• 8302.49 Certain other base metal mountings
• 8302.50 Hat racks and pegs
• 8302.60 Automatic door closers
• 8305.10.0050 Fittings for looseleaf binders
• 8306.30.0000 Ornamental picture frames
• 8414.59.6590 Certain axial fans
• 8415.90.80 Certain air conditioner parts
• 8418.99.80 Certain refrigeration condensing units
• 8419.50.5000 Certain heat exchange units
• 8419.90.1000 Parts of certain water heaters
• 8422.90.0640 Parts of certain dishwashers
• 8424.90.9080 Parts of certain equipment for dispersing liquids or powders
• 8473.30 Parts of certain data processing cases
• 8479.89.9599 Machines not otherwise specified
• 8479.90.8500 Parts for trash compactors
• 8479.90.9596 Parts for machines not otherwise specified
• 8481.90.90 Certain valves
• 8486.90.0000 Semiconductor fabrication machine parts
• 8487.90.0080 Machinery parts not otherwise specified
• 8503.00.9520 Certain parts for motors and generators
• 8508.70.0000 Vacuum cleaner parts
• 8513.90.2000 Battery-powered lamp parts
• 8515.90.2000 Welding machine parts
• 8516.90 Parts of certain heating equipment
• 8517.71.0000 Information transmission device parts (aerials)
• 8517.79.0000 Information transmission device parts (other)
• 8529.90.7300 Certain radar parts
• 8529.90.9760 Certain other non-radar audio-visual parts
• 8536.90.8585 Certain other electrical apparatus for switching or protecting electrical circuits
• 8538.10.0000 certain products for the control or distribution of electricity
• 8541.90.0000 Certain parts of semi-conductor devices
• 8543.90.8885 Parts of certain electrical machines and apparatus
• 8547.90 Certain insulating fittings
• 8708 Parts of certain motor vehicles
• 8807.30.0060 Aircraft parts for use in non-civil aircraft (not propellers and not undercarriages)
• 9013.90 Certain laser parts
• 9401.99.9081 Certain seats
• 9403 Certain metal furniture (other than office furniture)
• 9405.99 Lighting fittings
• 9506 Certain exercise equipment
• 9507 Certain fishing equipment
• 9603.90.8050 Certain brooms.

From the lists in this article, we can see that aircraft parts classified under Heading 8807 will typically be outside of the scope of the 25% duty on derivative products of aluminium, iron or steel (with the exception of certain non-civil aircraft parts, as shown). But aircraft parts classified under other HTSUS headings (as shown) could be subject to the 25% duty.

These tariffs are subject to change. The lists will probably both expand and contract in response to policy determinations by the US. You should use these lists as a starting point for your analysis, but you should always accurately classify your import goods and then perform a full legal analysis, using the most current version of the HTSUS.

This feature, minus the extensive lists above, was first published in MRO Management – April 2025. To read the magazine in full, click here.