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.
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:
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.
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.
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:
In general, imports that qualify under Section 321 (valued under $800) are not subject to 232 duties. However:
As listed in the Presidential Proclamation 9704, 7616.99.51.60 and 7616.99.51.70 are specifically subject to Section 232 duties.
Only HTS Codes defined in the Presidential Proclamations 9704 and 9705 should be reported for additional duty.
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.
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.
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:
Please refer to CBP’s quota bulletins for up-to-date information.
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.
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.
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 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 more information, please see Section 232 Investigations.
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.
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.
For guidance on submitting approved product exclusions to CBP, please refer to CSMS # 55844950.
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.
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.
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.
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.
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:
For aluminum derivative HTS codes:
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.
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.
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.
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.
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:
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:
To report sets in ACE, use entry summary lines grouped as follows:
Use the Article Set Indicator to indicate what each line represents:
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).
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:
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.