CBP Publishes Updated FAQs on Section 232 Tariffs

The FAQs serve as an important resource for importers navigating the revised rules, classifications, and exclusion procedures under the updated tariff framework.

The U.S. Customs and Border Protection (CBP) has updated its Frequently Asked Questions (FAQs) addressing Section 232 tariffs on aluminum and steel imports.

As of March 12, 2025, President Donald Trump has officially reinstated Section 232 tariffs, restoring the 25% duties on steel and increasing the aluminum duties from 10% to 25%.

The 25% tariffs, which come in addition to other applicable tariffs or duties, are enforced on all countries except Russia, which is subject to a 200% tariff on aluminum products and derivatives.

Below are key highlights of the CBP’s FAQs, which were last updated on March 21, 2025.

General information

Timing of duty calculation

For entries made under an immediate transportation entry, the applicable Section 232 duty rate is determined based on the date the entry was accepted at the port of original importation.

This follows the rule outlined in 19 CFR 141.69(b), which states that goods shall be subject to the rates in effect when the immediate transportation entry was accepted at the port of original importation.

However, this only applies to goods that are:

• Not subject to quota or tariff-rate quota, and
• Not placed into general order custody.

Drawback

As noted in CSMS # 18-000317, no drawback shall be available with respect to the Section 232 duties imposed on any aluminum or steel article.

Temporary Importation Bonds (TIBs)

Section 232 dutiable goods can be entered under a TIB, provided that the bond posted is sufficient to cover all applicable duties, taxes, etc., including 232 tariffs.

Foreign Trade Zones (FTZs)

Steel and aluminum products subject to Section 232 must be admitted into FTZs as “privileged foreign status” (per 19 CFR 146.41) unless they qualify as “domestic status” items.

It is important to note that:

• Goods manufactured in an FTZ are not automatically dutiable under Section 232 merely for this reason.
• Goods admitted to a U.S. FTZ in privileged foreign status will retain that classification status. 

De minimis shipments (Section 321)

In general, imports that qualify under Section 321 (valued under $800) are not subject to 232 duties. However:

• If the goods are subject to quota restrictions, Section 321 cannot be used, and the shipment must be entered formally.
• If the shipment includes goods subject to AD/CVD, they also require a formal entry and are not eligible for de minimis treatment.

Harmonized Tariff Schedule (HTS) classifications

Duties under HTS 7616.99.51

As listed in the Presidential Proclamation 9704, 7616.99.51.60 and 7616.99.51.70 are specifically subject to Section 232 duties.

Chapters 72, 73, and 76

Only HTS Codes defined in the Presidential Proclamations 9704 and 9705 should be reported for additional duty.

Chapter 98

Goods eligible under Chapter 98 are not exempt from Section 232 duties.

Importers can transmit up to 8 HTS codes on an entry summary line.  For more information on the proper order of reporting the HTS on an entry summary line, please refer to CSMS # 39587858. 

CBP has published further clarification for entries involving both Chapter 98 and Section 232 requirements. Please refer to CSMS # 42355735 for guidance on correct coding practices and examples.

Chapter 99

Only HTS Codes specified in Section 232 Presidential Proclamations must be reported along with the corresponding Chapter 99 HTS for additional duty or quota or the relevant product exclusion ID number. 

General Approved Exclusions (GAEs)

Section 232 GAEs are not retroactive, and importers are required to only report the corresponding Chapter 99 HTS for the GAEs otherwise subject to a quota.

When filing under a duty-based GAE:

• Only report the excluded 10-digit HTS code.
• Do not report the Section 232 Chapter 99 HTS classification or exclusion number.

Please refer to CBP’s quota bulletins for up-to-date information.

Free trade agreements and special duty programs

Goods that qualify for Free Trade Agreements (such as USMCA) or other special programs (like GSP or AGOA) are still subject to Section 232 duties.

GSP and AGOA can be claimed on any goods that are subject to a valid Section 232 exclusion. However, GSP or AGOA cannot be claimed on entries subject to Section 232. 

Product exclusions

Status of approved exclusions

CBP publishes a weekly list of active product exclusions on its website. This list, which is updated every Friday, determines which exclusions are active in ACE.

If an exclusion appears on the list, no additional activation request needs to be submitted to CBP.

IOR mismatch for Post Summary Correction (PSC)

You can determine if CBP has activated an approved Importer of Record (IOR) name change request by filing an entry with a Section 232 exclusion.

“IOR MISMATCH” indicates that the IOR number used for the filing does not match the IOR approved for the exclusion. 

If you receive this error, please contact your CBP client representative.

If you need to make any corrections or updates to the approved IOR for the exclusion, reach out to the U.S. Department of Commerce using the following contact details: 

• For steel: (202) 482-5642 or steel232@bis.doc.gov
• For aluminum: (202) 482-4757 or aluminum232@bis.doc.gov

Changes to Section 232 exclusions

For any request for changes to an approved exclusion or an exclusion application, reach out to the U.S. Department of Commerce using the following contact details:

• For steel: (202) 482-5642 or steel232@bis.doc.gov
• For aluminum: (202) 482-4757 or aluminum232@bis.doc.gov

For more information, please see Section 232 Investigations.

Exclusion validity

A product exclusion is typically valid for one year from the date of signature or until the granted quantity is fully used—whichever comes first.

“TRFF ADJSTMNT HTS OR EXCLSN MISSING” error

This error may indicate that one of the entry summary lines on the entry beginning with Chapter HTS 72, 73 or 76 may be subject to Section 232 and/or 301 duties. 

If you encounter this error, please contact your CBP Client Representative or your assigned Center of Excellence and Expertise.

Submitting approved exclusions

For guidance on submitting approved product exclusions to CBP, please refer to CSMS # 55844950.

Remaining exclusions balance

Importers and brokers can use ACE to create custom reports and track how much of their excluded product they have imported.

The importer of record is responsible for monitoring this and ensuring that the imported quantity does not exceed the approved limit.

Any amount imported beyond the approved limit will be subject to the additional Section 232 duty or quota. 

Additional clarifications

Reporting derivative steel

If the importer does not know the country of melt and pour for derivative steel that is subject to Section 232, they can report OTH as the country.

Reporting derivative aluminum

If the importer does not know the country of smelt or cast for derivative aluminum, they can report RU (Russia) as an interim solution and pay the 200% Russian aluminum duty in accordance with Presidential Proclamation 10522.

Importers can later file a Post Summary Correction to update the actual country data once it is available.

The CBP is working on a long-term fix for unknown smelt/cast reporting and will issue guidance through CSMS when an update is available.

Minimum steel/aluminum content

For steel and aluminum derivatives subject to HTS 9903.85.08 and HTS 9903.81.91, there is no minimum content threshold to be subject to Section 232 duties, as provided for under Proclamations 10895 and 10896.

Reporting melt and pour/smelt and cast

If the product does not contain steel or aluminum content but has an HTS classification that would be subject to Section 232 measures on derivative steel or aluminum articles if it contained steel or aluminum, ACE will still require the steel melt and pour or aluminum smelt and cast country to be reported.

For steel derivative HTS codes:

• Report the country of origin of the non-steel product as the steel melt and pour country.

For aluminum derivative HTS codes:

• Report “Y” as the secondary smelt country code,
• And report the country of origin of the non-aluminum product as the secondary smelt country and as the country of cast.

If a good has an HTS classification subject to Section 232 measures on derivative steel and aluminum measures, and it contains steel or aluminum content, see CSMS # 64384423 and CSMS # 64384496 for reporting instructions.

Reporting decimal values

Filers can report quantities less than 1 and may use up to two decimal places (e.g., 0.25 or 1.10).

Please refer to the CATAIR - Tariff/Value/Quantity Detail (Input 50-Record) for guidance on formatting. 

Aluminum certificate of analysis

CBP does not require an aluminum certificate of analysis at the time of entry. However, it may be requested during post-entry reviews or enforcement.

Importers are expected to exercise reasonable care and declare goods truthfully and accurately at the time of entry. Moreover, all classification and documentation must be supported by verifiable records. 

Determining steel and aluminum value

Valuation of aluminum or steel content follows the Customs Valuation Agreement under 19 U.S.C. 1401a.

The value should reflect the total price paid or payable for the steel or aluminum content, excluding freight, insurance, and similar costs.

This is usually based on the invoice paid by the buyer of the steel or aluminum content or for the benefit of the seller of the steel or aluminum content. 

Assessing duties with respect to “sets”

When importing goods in sets for retail sale, Section 232 duties apply depending on how the set is classified under the HTSUS and what item gives it its essential character. This is determined under the General Rule of Interpretation (GRI) 3.

If the product that gives the set its essential character is subject to Section 232:

• The entire set is subject to the additional ad valorem duty.
• The Chapter 99 HTSUS number for Section 232 must be reported on the same entry summary line as the Chapter 1–97 classification.

If the HTSUS provision for the set is not subject to Section 232, even though the set contains components that are classifiable under Chapter 99 of the HTSUS:

• No Section 232 duty is applied.

To report sets in ACE, use entry summary lines grouped as follows:

• One Article Set Header, and
• Two or more Article Set Components.

Use the Article Set Indicator to indicate what each line represents:

• Not specified (i.e. space) to indicate that the single Entry Summary Line Item represents a single article (i.e., not part of a set).
• Specified as ‘X’ to indicate that the Entry Summary Line Item is part of an article ‘set’ and specifically the ‘Article Set Header.’
• Specified as ‘V’ to indicate that the Entry Summary Line Item is part of an article ‘set’ and specifically an ‘Article Set Component.’

The Article Set Header should use the classification that reflects the product’s essential character, as determined by the importer.

The dollar value reported for the header must be the total of all the individual component dollar values in the set (the parts of the set).

Next steps for U.S. importers

With the enforcement of Section 232 tariffs, importers must ensure accurate classification, timely filing, and proper use of exclusions to avoid delays or penalties by:

• Reviewing CBP’s latest guidance and CSMS updates regularly.
• Monitoring exclusion usage and quantities.
• Working closely with a customs broker to classify goods accurately and ensure compliance. 

How Cole International can help

At Cole International, we offer customs and compliance consulting services to help businesses navigate changing regulations and identify tariff classifications for their imports.

We also provide timely and efficient customs brokerage services to facilitate the entry of goods into the U.S.

If you import steel or aluminum into the U.S., please reach out to one of our trade professionals to discuss how to ensure compliance and expedite your import processes in light of the new Section 232 tariffs.