I. Background

On June 16 (Eastern Time), the U.S. Department of Commerce issued an official announcement deciding to modify the scope of tariffs on steel derivatives.From June 23, it will include eight categories of home appliances classified as steel derivatives in the Section 232 tariff scope, including combination refrigerators, dryers, washing machines, dishwashers, freezers, cooking stoves and electric ovens, kitchen waste disposers, and welded metal racks. The tariff scope announced in this document only involves steel derivatives, not aluminum derivatives.

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According to the China Chamber of Machinery and Electronics Industries (CCMEI), on March 5, 2025, the U.S. Department of Commerce issued the Announcement on Implementing Steel Tariffs based on Presidential Proclamation No. 10896 of February 10, 2025: Adjusting U.S. Steel Imports, and Annex 1 to the announcement listed the steel derivatives subject to Section 232 tariffs. This tariff expansion is an addition to the scope specified in Annex 1, involving only steel derivatives. Meanwhile, the two presidential proclamations issued by the U.S. on February 10, 2025 (Proclamation No. 10895 and No. 10896) regarding adjustments to U.S. steel and aluminum imports also required the U.S. Department of Commerce to establish an "inclusion process" to add more "steel and aluminum derivatives" to the Section 232 tariff scope in a timely manner. On May 2, 2025, the U.S. Department of Commerce announced a public comment period for this "inclusion process," which closed on June 16, 2025. According to CCMEI, the U.S. had previously announced additional Section 232 tariffs on imported steel products, including air conditioning parts and refrigerator parts, and on June 3, 2025, it announced increasing the tariff rates on steel, aluminum, and their derivatives from 25% to 50% (except for the UK). The 50% additional tariff on the above-mentioned home appliances and other steel derivatives means that the scope of U.S. steel tariffs has expanded from parts to complete machines, which may significantly affect the export of these home appliances to the U.S.

CCMEI reminds that for products within the adjusted tariff scope, the steel content and non-steel content must be strictly distinguished. For specific products, only the steel component is subject to Section 232 tariffs. According to relevant U.S. announcements, the steel components of products are subject to Section 232 tariffs but not "reciprocal tariffs"; non-steel components are not subject to Section 232 tariffs but will be levied "reciprocal tariffs."

II. Analysis of Trade Scale of Products Involved

According to CCMEI statistics, the total import value of the above-mentioned taxed products by the U.S. from the global market in 2024 was $15.04 billion, of which $2.91 billion was imported from China.

III. Export Situation of Involved Categories

Based on customs data, CCMEI statistics show:

In 2024, China's export value of refrigerators and freezers (including parts) to the U.S. was $3.16 billion, up 20.6% year on year, making the U.S. the largest export market, accounting for 17.3% of the total export value of this category. Among them, other refrigeration equipment (HS 841869) accounted for $780 million, and combined refrigeration-freezing units (HS 841810) accounted for $720 million, together accounting for 47.5% of the export value.

In 2024, China's export value of complete dryers to the U.S. was $74.388 million, up 5% year on year, with the U.S. as the largest export market, accounting for 10.1% of the total export value. The export volume to the U.S. was 479,000 units, up 22% year on year, accounting for 10.3% of the total export volume.

In 2024, China's export value of washing machines (including parts) to the U.S. was $530 million, down 0.2% year on year, making the U.S. the second-largest export market, accounting for 8.3% of the total export value. Among them, washing machines with a drying capacity of more than 10 kg (HS 845020) accounted for $390 million, up to 73% of the total.

In 2024, China's export value of complete dishwashers to the U.S. was $165 million, down 1.8% year on year, with the U.S. as the second-largest export market, accounting for 14.9% of the total export value. The export volume to the U.S. was 986,000 units, up 6.5% year on year, accounting for 13.9% of the total export volume.

In 2024, China's export value of complete electric ovens to the U.S. was $1.58 billion, up 1.0% year on year, with the U.S. as the largest export market, accounting for 19.3% of the total export value. The export volume to the U.S. was 66.634 million units, up 18.3% year on year, accounting for 17.9% of the total export volume.

In 2024, China's export value of complete kitchen waste disposers to the U.S. was $44.784 million, up 4.8% year on year, with the U.S. as the largest export market, accounting for 48.8% of the total export value. The export volume to the U.S. was 1.42 million units, down 6.3% year on year, accounting for 70.8% of the total export volume.

Except for electric ovens, the export values of the above products to the U.S. showed a fluctuating upward trend from 2019 to 2024.

IV. The Tariffs Will Increase Duties on Involved Products

The U.S. tariffs on the above products apply to all imports, and even products produced in Mexico, a party to the USMCA, are included in the tariff scope. The U.S. imports a higher share of refrigerators, dryers, ovens, and other products from Mexico than from China.

It is worth noting that the U.S. imposes Section 232 tariffs on the steel components of imported home appliances but not "reciprocal tariffs"; non-steel components are not subject to Section 232 tariffs but are subject to "reciprocal tariffs."

According to calculations, the tariff increase for home appliances with high steel content is limited. CCMEI estimates that if a Chinese-exported refrigerator costs $100 per unit and the steel component accounts for 30%, the tariff calculation formula after the new steel component tariff is:

*Tariff = $70 × 55% (10% reciprocal tariff + 20% fentanyl-related tariff + 25% Section 301 tariff) + $30 × 95% (20% fentanyl-related tariff + 25% Section 301 tariff + 50% Section 232 tariff)*.

The tariff for this refrigerator exported to the U.S. will increase from 55% to 67%. Therefore, for home appliances with a steel content of 15%, the tariff increase is relatively limited.

V. Enterprises Need to Assess Impacts and Respond Proactively

China is the world's largest producer of home appliances, and the U.S. is a major global consumer market and importer. The U.S. tariffs this time involve areas where China's home appliance industry has rapid technological upgrading and increasing market share. Coupled with previous trade restrictions, these tariffs will further push up the selling prices of local products in the U.S., suppress local sales, and increase uncertainties in the global home appliance trade and industrial chains. Relevant enterprises need to systematically assess the impacts and respond proactively.