April 27 Federal Register: New HTSUS 9903.82.01 for Non-Metal Derivatives Containing Steel/Aluminum
On April 27, 2026, the Department of Commerce published a Federal Register notice modifying Chapter 99 of the HTSUS to add new heading 9903.82.01 — covering articles listed under U.S. Note 16 that do NOT contain aluminum, steel, or copper. The change is part of the broader Section 232 derivative-product overhaul that took effect April 6 and impacts importers of products that previously fell into ambiguous tariff classification territory.
If you import derivative products that get named in Note 16 but don't actually contain the metals — think furniture with non-metal hardware, electronics in plastic enclosures, plumbing fittings made entirely of polymer — this notice tells you exactly where to file your entry.
What HTSUS 9903.82.01 Covers
The new heading is narrowly scoped but commercially important. It applies to articles that:
- Are listed by description in U.S. Note 16 to subchapter III of Chapter 99
- Do NOT contain any aluminum, steel, or copper content
- Would otherwise have been forced into a metal-tariff Chapter 99 code by virtue of their product description
In plain English: the article matches the name of a Section 232 derivative product, but it isn't actually made of the covered metal. Without 9903.82.01, importers of these goods were stuck declaring a metal-tariff code on a product with zero metal content — a misclassification waiting to happen.
Why This Matters
Before the April 6, 2026 restructure, Note 16 derivatives lived in a sprawling set of Chapter 99 codes: the old 9903.80.*, 9903.81.*, 9903.85.*, and 9903.78.* families. The April 6 reorganization consolidated those into the new 9903.82.* family — but the consolidation initially had no clean home for products that were named in the derivative list but didn't contain the metal.
Examples of where this gets confusing in practice:
| Product | Pre-April 6 | April 6–26 | April 27 onward |
|---|---|---|---|
| Steel furniture (with metal frame) | 9903.81.* | 9903.82.0X (metal rate) | Same |
| Furniture named in Note 16 but all-plastic | 9903.81.* (ambiguous) | Unclear | 9903.82.01 |
| Electronics housing in steel | 9903.81.* | 9903.82.0X | Same |
| Same housing, polymer instead | Ambiguous | Ambiguous | 9903.82.01 |
The new 9903.82.01 heading gives importers and brokers a clean, defensible place to classify the no-metal version of an otherwise covered article.
Effective Date and How to Apply
The technical correction was published April 27 and applies to entries filed on or after the publication date. To declare under 9903.82.01:
- Confirm the product is listed by description in U.S. Note 16
- Document that the product contains zero aluminum, steel, or copper (mill certs, BOMs, supplier statements)
- Declare the appropriate underlying HTS classification (Chapters 72, 73, 74, 76, 84, 85, 87, 94, etc.)
- Add 9903.82.01 as the Chapter 99 reporting flag
- Pay the underlying duty rate only — no Section 232 metal tariff applies
Background: The April 6 Section 232 Derivative Restructure
For readers just catching up: April 2's presidential proclamation, effective April 6, 2026, restructured how Section 232 metal tariffs apply to derivative products. The headline changes:
- Tariffs now apply to full customs value, not just metal-content portion
- 50% rate for primary articles (steel, aluminum, copper)
- 25% rate for most derivative products (with full-value application)
- Old 9903.80., 9903.81., 9903.85., and 9903.78. consolidated into 9903.82.*
The April 27 addition of 9903.82.01 closes a gap that brokers had been flagging since April 6.
Who's Affected
Importers most likely to use 9903.82.01:
- Furniture importers bringing in pieces named in Note 16 but made entirely of wood, plastic, or composite
- Electronics importers with product descriptions matching Note 16 but enclosures in polymer or ceramic
- Plumbing and fittings importers with polymer or PEX-only assemblies
- Auto-parts importers with non-metal versions of named components (gaskets, trim, mounts)
- Appliance importers for sub-assemblies that are named but not metal
If your supplier ships you a product that looks like a Section 232 derivative on paper but the bill of materials shows no metal, this is your heading.
Action Items
- Review your Chapter 99 classifications for any entries filed since April 6 where your product is named in Note 16 but contains no aluminum, steel, or copper
- Document metal content with mill certificates, BOMs, and supplier declarations — CBP will ask for evidence
- Update your entry summary templates to include 9903.82.01 as an option for qualifying SKUs
- Brief your customs broker on which SKUs in your catalog should map to 9903.82.01 vs. 9903.82.04/05/06
- Audit prior entries filed April 6–27 where you may have over-declared on a metal-tariff code
Common Misclassification Risks
Three patterns that trip up importers:
- Naming match without metal match. A product called "steel chair" in Note 16 doesn't have to contain steel. If yours doesn't, 9903.82.01 is your code, not 9903.82.04.
- Trace metal in fasteners. A wood chair with steel screws may still have meaningful steel content. Document the percentage. If it's substantive, 9903.82.01 doesn't apply.
- Mixed-material SKUs in one entry line. Don't average across SKUs. Each line item gets its own classification based on its own metal content.
Sources
Federal Register: Notice of Technical Corrections to HTSUS for Duties Imposed by Presidential Proclamation 11021 | USITC Harmonized Tariff Schedule | White House: Fact Sheet on Steel/Aluminum/Copper Strengthening | GHY: U.S. Adjusts Section 232 Tariffs on Aluminum, Steel and Copper
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