CBP Updates Section 232 Aluminum Reporting Guidance for Unknown Country of Smelt and Cast

The new guidance eliminates ambiguity by allowing “UN” to be used instead of placeholder ISO country codes. However, a 200% duty rate applies in this case.

CBP has issued new guidance for importers on completing Section 232 aluminum reporting when the country of smelt and cast is unknown.

The update, which will take effect on June 28, 2025, requires filers to report “UN” (for Unknown) in ACE when origin information is not available.

This replaces previous instructions, where importers of aluminum derivatives were required to enter an ISO country code—even when the country of smelt and cast was unknown.

CBP had previously directed filers to choose any valid ISO country code other than “US” and permitted them to submit a Post-Summary Correction (PSC) once the correct information became available. 

200% duty applies for unknown country of smelt and cast

According to the updated guidance, when importers report “UN” instead of an ISO country code for smelt or cast, they must also report the appropriate HTS code (either HTS 9903.85.67 or HTS 9903.85.68).

The entry will be assessed the 200% Section 232 duty, which is the same rate applied to aluminum imports from Russia. 

Reporting requirements

As part of Section 232 aluminum reporting obligations, importers must declare the following using valid ISO codes:

• Primary country of smelt — the country where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) using the electrolytic Hall-Héroult process.
• Secondary country of smelt — the country where the second largest volume of new aluminum metal is produced from alumina by the same electrolytic process.
• Country of most recent cast — the country where the aluminum (with or without alloying elements) was last liquified by heat and cast into a solid state.

When submitting entries through ACE, importers must report “Y” for the primary and/or secondary country of smelt. Reporting “N” for both fields is not permitted.

For the Importer's Additional Declaration Record Type '07', if either the derivative aluminum primary and/or secondary country of smelt or country of cast is unknown, importers must report ‘UN’ for the ISO country code.

ACE updated and new error codes added

CBP has updated the ACE Entry Summary Create/Update CATAIR (v105) with additional technical details and reporting requirements to support the new Section 232 aluminum reporting procedures.

Moreover, the Entry Summary Error Dictionary now includes two new error codes:

• 856 – UNKNOWN ALUM SMELT/CAST CTRY NOT ALLOWED
• 60B – HTS REQUIRED FOR UNKNOWN SMELT/CAST CTRY 

Next steps for U.S. importers

If you import aluminum derivatives into the U.S., we recommend you take the following steps ahead of the June 28 enforcement date:

• Speak to your suppliers to identify the source of your aluminum wherever possible.
• Review your supply chain documentation to confirm if smelt and cast country data are available.
• Consult your customs broker for guidance on using the relevant HTS codes and applying the correct duty rate.

How Cole International can help

At Cole International, we constantly monitor changing trade regulations and offer customs and compliance consulting services to help businesses navigate these changes.

Additionally, we provide timely and efficient customs brokerage services to help U.S. importers streamline their customs clearance and other import processes.

Please reach out to one of our trade professionals to discuss how we can help you review your aluminum import data and ensure compliance with the updated Section 232 aluminum reporting requirements.