UPDATE: JUNE 9, 2025:
This article was revised to reflect the CBP’s recently published Federal Register guidance that included revised Steel and Aluminum HTS codes.
CBP PUBLISHES GUIDANCE FOR EXPANDED SECTION 232 STEEL, ALUMINUM, AND COMPOSITE IMPORT DUTIES
U.S. Customs and Border Protection (CBP) recently issued updated entry guidance following the June 3 proclamation that raised Section 232 tariffs on most imported steel and aluminum from 25% to 50%. The guidance outlines how duties will now be assessed, how composite goods must be reported, and what importers must do to ensure compliance.
Effective June 4, 2025, the 50% duty applies only to the declared value of steel or aluminum content, not the full value of the article, provided entries are reported correctly.
CBP REQUIRES CONTENT BREAKDOWNS FOR COMPOSITE GOODS
Importers must now declare metal and non-metal content separately. When value segmentation is unavailable, the full duty applies to the entire article. If content values are known, entries must report two lines: one for the non-metal portion and one for the steel or aluminum portion, each carrying the applicable Chapter 99 HTS designation.
CBP expects complete HTS declarations and supporting documentation. Failure to segment entries properly may result in penalties, audits, or suspension of import privileges.
EXPANDED HTS COVERAGE INCLUDES DERIVATIVE ARTICLES
CBP noted that Section 232 duties now apply to a broader range of goods:
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Derivative articles may fall outside Chapters 72, 73 (steel) or 76 (aluminum) and still trigger the 50% duty.
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Exemptions for U.S.-origin metal still apply but require documented evidence of melt-and-pour (steel) or smelt-and-cast (aluminum).
- Russian-origin aluminum is still subject to a separate 200% duty and must be reported under distinct HTS codes not covered by standard Section 232 treatment.
Importers must confirm classifications, especially for composite assemblies or processed goods.
FTZ AND BONDED STRATEGIES STILL APPLY, WITH LIMITATIONS
Foreign Trade Zone (FTZ) and bonded warehouse programs remain effective for duty deferral, but goods must be granted privileged foreign status before entry for consumption. FTZ admissions after June 4 will be assessed at the new 50% rate unless otherwise exempted.
NEXT STEPS FOR U.S. IMPORTERS TO ENSURE SECTION 232 COMPLIANCE
Importers should review the following to remain compliant:
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Verify HTS classifications against updated steel and aluminum tariff schedules, including derivative articles.
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Segment content values for composite goods and report under separate entry lines with correct HTS codes.
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Secure melt-and-pour or smelt-and-cast certifications in advance of customs filing.
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Evaluate landed cost impact under the new tariff structure and update procurement, planning, and sales models accordingly.
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Confirm duty deferral eligibility for any inventory held in FTZ or bonded warehouse locations.
CBP stated that full compliance is expected and enforcement is imminent. Importers operating in automotive, construction, aerospace, and industrial sectors should ensure readiness across both supply, compliance, customs processes.
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