A refrigerator, dishwasher or appliance component does not have to be named in the original Section 232 steel and aluminum actions to end up under the tariffs. The Commerce Department has a recurring process that lets U.S. producers and their industry associations ask the government to add downstream products containing steel or aluminum — and gives importers, manufacturers and other interested parties a short window to respond.
The mechanism matters to the appliance business because it has already reached finished products. In June 2025, the Bureau of Industry and Security added combined refrigerator-freezers, chest and upright freezers, dishwashers, washing machines, clothes dryers, certain food-waste disposals, electric cooking stoves and ovens, and certain wire racks to the steel-derivative tariff list. That action showed how a trade measure centered on metals can move downstream into appliance HTS codes.
Who Can Ask Commerce to Add a Product
Under the BIS inclusion procedures, a request can come from a U.S. producer of steel or aluminum articles, a U.S. producer of derivative steel or aluminum articles, or an industry association representing one or more such producers. The Secretary of Commerce also has authority to add derivative products without an industry request.
That distinction is important for appliance companies. The process is not a general petition system in which any importer can ask Commerce to place a competitor’s product under Section 232. Eligibility to file an inclusion request is tied to domestic production, although the later public-comment stage gives other interested parties an opportunity to address a request.
BIS established two-week submission windows three times a year, at the beginning of January, May and September. Requests are submitted to the agency in PDF form and are limited to 30 pages including attachments.
A Request Needs More Than a Product Name
The filing requirements force a requester to define both the product and the trade case for adding it. A valid request must identify the applicant, precisely define the derivative article and specify the eight- or 10-digit Harmonized Tariff Schedule of the United States classification proposed for inclusion.
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The requester must also explain why the product qualifies as a steel or aluminum derivative article. To the extent practicable, BIS asks for the value of the product’s steel or aluminum content as a share of its total value. The filing must include information about the affected domestic industry, statistics on imports and domestic production, and an explanation of how imports threaten to impair national security or otherwise undermine the objectives of the 2018 steel and aluminum Section 232 investigations or related presidential proclamations.
For an appliance manufacturer or component supplier evaluating a petition, the HTS classification is therefore central. Section 232 treatment can attach to an entire tariff classification even though individual products within the commercial market may differ in metal content, sourcing and manufacturing footprint.
BIS Opens a 14-Day Public Comment Window
BIS first checks requests for required information and the page limit. The rules allow the Under Secretary for Industry and Security, at discretion, to give a filer 48 hours to correct an incomplete or improperly filed submission.
After a submission window closes, BIS posts nonconfidential versions of valid requests to Regulations.gov docket BIS-2025-0023 for a 14-day public-comment period. Business-confidential material requires a separate public version.
That 14-day period is the key monitoring point for appliance importers, manufacturers, retailers and trade groups that may be affected by a proposed addition. Comments can address the request’s product definition, tariff classification, import and domestic-production evidence, derivative status and national-security rationale. Because the window is short, companies that wait for a final Federal Register notice have missed the formal opportunity to comment on the underlying request.
Commerce Has 60 Days to Decide
BIS begins analyzing accepted requests when the public-comment phase starts. The agency evaluates whether the product identified at the eight- or 10-digit HTSUS level is a derivative steel or aluminum article and whether its imports have increased in a way that threatens national security or otherwise undermines the objectives of the Section 232 investigations or related proclamations.
The Secretary of Commerce or a designee makes a positive or negative determination. BIS is required to post a determination memorandum for each request within 60 days of receiving the accepted request, stating whether it was approved or denied and summarizing the rationale.
An approval is not the final administrative step. Commerce then publishes a Federal Register notice modifying the relevant tariff annex at the eight- or 10-digit HTSUS level, and the new duties take effect through coordination with U.S. Customs and Border Protection.
Appliances Show How Far Section 232 Can Reach
The appliance industry’s exposure became concrete in June 2025. Commerce revised the steel-derivative annex to add multiple appliance classifications, including HTSUS 8418.10.00 for combined refrigerator-freezers, 8422.11.00 for dishwashers, 8450.11.00 and 8450.20.00 for washing machines, 8451.21.00 and 8451.29.00 for dryers, and 8516.60.40 for electric cooking stoves and ovens, among other products. The additions took effect June 23, 2025.
Those additions were made by Commerce rather than through the later public-request rounds, illustrating a second source of exposure: the Secretary’s authority to add derivative products directly. The recurring inclusion process creates another route by which the tariff perimeter can expand.
For appliance companies, that makes tariff monitoring a product-classification exercise as much as a headline-watching exercise. A practical watch list includes the BIS Section 232 steel and aluminum hub, docket BIS-2025-0023 on Regulations.gov, Commerce determination memoranda and Federal Register notices that change the tariff annexes. Companies should also track the HTSUS codes used for finished appliances and imported components rather than relying only on product names.
The process does not mean every requested product will be tariffed. It does mean that the list can change on a recurring schedule, with only 14 days for public comments once accepted requests are posted. For manufacturers and importers with significant steel- or aluminum-containing products, that calendar can determine when a proposed tariff moves from an industry filing to a landed-cost issue.
