U.S. Customs and Border Protection (CBP) is refining how metal content should be calculated for Section 232 tariff reporting. In informal notification to carriers, CBP provided guidance explaining that the current interpretation maintains the framework used for steel and aluminum, aligns copper with that methodology. The informal guidelines also introduces additional clarification on the treatment of iron.
HOW IS METAL CONTENT VALUE DETERMINED UNDER SECTION 232?
Section 232 duties continue to apply based on the value of metal contained within an imported article. For goods that are wholly composed of steel or aluminum, duties apply to the full entered value. Where articles contain both metal and non-metal components, importers may separate content value when there is a clear distinction between materials. However, production-related costs such as manufacturing, labor, overhead, profit, and packaging remain part of the metal content value and are not excluded.
HOW ARE COPPER AND IRON TREATED UNDER THIS INTERPRETATION?
Copper and copper alloys are evaluated using the same content valuation methodology as steel and aluminum. Importers are not permitted to break down chemical composition to remove alloying elements from the dutiable value. CBP also indicated that iron content is determined using the same framework. At the same time, certain iron articles, including cast iron, pig iron, and wrought iron, may fall outside the scope of Section 232 depending on classification. Importers may not isolate iron content within steel articles to reduce duty exposure.
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