Section 232 derivative guide, Part 1: Appliances, vehicles and tools

Some of those categories span products for the home consumer to the commercial and industrial manufacturer. But the bottom line is that costs will go up.

HVAC

Aluminum is ubiquitous in heating, ventilation, and air conditioning (HVAC) equipment and home appliances. The new list explicitly includes air conditioning machines and parts (HTS 8415 series) and house household refrigeration appliances (HTS 8418 series).

HVAC units use evaporator coils, condenser coils, and heat exchangers typically made of aluminum tubing and fins, which in many cases were imported to meet U.S. demand.

These include HVAC components used for automotive applications. Manufacturers and suppliers of HVAC components voiced concern rapidly shifting to domestic alternatives will be difficult as qualifying a new supplier for critical aluminum components like air conditioning evaporators could take as long as three years due to stringent automotive quality control, such as the production part approval process (PPAP) and advanced product quality planning (APQP) certifications validation processes.

Also included are cooling plates and radiators (HTS 8419.50.1000) used in electric vehicles consisting of stamped aluminum alloy plate, sometimes clad sheet, that are brazed together to form battery chillers or engine charge-air coolers.

What’s in your fridge

Home appliance makers will face similar calculations. A standard refrigerator-freezer contains around 2-5 pounds of die-cast parts per unit alone. That doesn’t include the rolled products involved.

Here’s some perspective: Using CRU’s July midpoint assessment of A380 ingot at $1.25-$1.26 per pound as a proxy for the most common die-cast alloy, a typical refrigerator-freezer carries about 3.5 pounds of die-cast content. Assuming 55% of the U.S. market is supplied by foreign-produced units, and with total U.S. sales estimated at 6 million units, according to the North American Die Casting Association, the tariff impact adds up quickly.

Even before accounting for machining, tooling, and labor costs to work the A380 secondary alloy further down the value chain, these assumptions translate to more than $7 million in additional tariff costs annually—purely from the imported die-cast aluminum content.

Of course, the impact extends beyond refrigerators. For dryers, the added tariff burden comes to just under $4 million, while imported washing machines account for just under $5 million in additional costs. These estimates reflect the market as it stands today, assuming no shifts in supply chain dynamics.

Additionally, these are just die-cast products and do not include the 3003 sheet used in the manufacturing of refrigerator liners and panels, 1100 fin stock used in all sorts of HVAC manufacturing, as well as unique alloys with limited or domestic production like 5086 used in refrigeration or 8006 fin stock.

Hand-tools and machinery

A broad array of tools and machinery was swept into the expanded tariff annex. This includes many hand-held and power tools under HTS 8467 series codes, such as circular saws, chainsaws, sanders, routers, and even lawn equipment.

Many of these tools employ high-speed steel or specialty/stainless steel products with the appropriate alloying agents for heavy working, like cobalt, molybdenum, vanadium, etc. And they commonly feature aluminum alloy housings, gearboxes, or engine parts to reduce weight.

For instance, a gas-powered chainsaw average about a pound and a half of aluminum die-castings, while electric hand tools can average just under a pound of castings, despite their hand-held status and aluminum’s use for lightweighting purposes.

While these are fairly modest volumes in terms of aluminum tonnages, unlike consumer durables and white goods with a roughly evenly split sales between imported products and those produced in the U.S., most electric hand tools, chainsaws, and the other goods that fall under this tariff schedule are produced abroad. In fact, the products that fall under the expanded HTS codes serving this end sector accounted for more than 80,000 metric tons of imported aluminum castings.

Truck-trailer

Automotive sector imports were largely covered by the Section 232 tariffs specifically concerning automobiles and auto parts, following their staggered implementation in April and May, respectively.

Those tariffs were mostly meant for the passenger vehicle segment, leaving out large swathes of the commercial vehicle market, like big-rigs, refrigerated vans, and tractors.

Now, the entirety of the tractors (HTS 8701 series) and work vehicles (HTS 8705 series) are included. These levies will mostly have an impact for importers paying for the steel content contained relative to aluminum, as the parts of these heavy, typically weight-ambivalent vehicles were already included under another expanded, yet smaller, scope implemented back in June.

That said, the widened provision for trailers and semi-trailers used in the transport of goods—HTS 8716.39.0040 series—will likely have a major impact, despite the specificity of the HTS code.

Unlike the Section 232 provisions aimed at passenger vehicles and their auto parts, which allow for a USMCA-compliant content threshold, these tariffs specifically cite that the aluminum content contained must have been poured and melted in the U.S.

That means the aluminum content in those Mexican-built trailers and extrusion-based walls, roofing, floor runners, will face a 50% duty at the U.S. border. Trailer manufacturers Wabash, Strick Trailers, Stoughton Trailers, and Great Dane led the petition for the inclusion of these products on the grounds that it would neutralize some of the cost advantage of Mexican production.

The measure will likely impact the largest producer of van trailers in North America, Hyundai Translead, which operates in Tijuana, Mexico, who strongly opposed the tariff. Hyundai Translead argued U.S. trailer builders themselves rely on global supply chains, often sourcing aluminum extrusions and components from abroad. In public comments, Hyundai noted that one of Wabash’s key extrusion suppliers is Nanshan America, a Chinese-owned plant in Indiana, while noting another petitioner, Stoughton Trailers, uses Chinese-manufactured axles, tires, and imported composite panels.

Moreover, two major trailer brands that petitioners cited as “American”, Utility Trailer Manufacturing Company and Fruehauf North America, manufacture in Mexico as well. The parent company of Fruehauf NA is Mexican-owned, and both firms build trailers under USMCA rules.

Around two-thirds of aluminum content used to manufacture truck-trailers is comprised of extrusions, while around one-third is made up of sheet and coil products, according to data from ACT Research.

Trailer roof coils are often produced using 3003 coil, 6XXX series forgings and extrusions like 6061 wheels 6005 chassis beams, and a handful of unique 5XXX series flat-rolled like 5086 and 5754 alloys used in floors.

Lithographic plate

Among the myriad products subject to aluminum content tariffs, one stands out as possibly the most unique for the scrap market.

Aluminum lithographic printing plates (HTS 3701.30.0000) is a distinct product largely relegated to bygone years.

These plates, used in offset printing, employ flat sheets comprising at least 90% aluminum by weight.

The aluminum substrate used in plate production is typically an extremely high-purity alloy, most often rolled from lithographic sheet coil, commonly 1050 alloy. This material dominates the raw material cost of plate production, which explains its importance in the scrap market as a “cutter-grade” scrap used to bolster aluminum content in melt mixes.

Imports of lithographic sheet were already covered under Section 232 tariffs implemented in 2018, classified under the 7606 heading. Since then, U.S. production capacity for lithographic sheet has waned, and many domestic mills with the technical capability have shifted their production lines toward other product mixes instead.

Eastman Kodak’s Columbus, Georgia, facility is the last remaining commercial U.S. manufacturer of such aluminum-based offset plates.

Kodak’s submission to the Department of Commerce noted that U.S. plate import volumes have surged to unprecedented levels, especially during and after the pandemic.

This import wave coincided with a major competitor shifting its plate manufacturing from the U.S. to Asia, a clear reference to Fujifilm, which closed its South Carolina plant in 2022.