Recent updates to Section 232 tariffs have significantly increased the cost and complexity of importing aluminum, steel, and copper into the United States. Steel imports are now generally subject to a 50% tariff, except for UK-origin goods, which remain at 25%. Aluminum imports face a 50% tariff when the country of smelt and cast is properly declared, but a steep 200% tariff applies if that origin is unknown. Copper, newly added under Section 232, is subject to a 50% duty on semi-finished and derivative goods.
The lists of HTS classifications affected under each Section 232 provision are subject to change. New classifications, including those for derivative articles, can be added with little advance notice, broadening the scope of the applicable tariffs. These changes impose stricter reporting and valuation requirements on importers.
Key Data Elements for Compliance
For Section 232 compliance, U.S. importers must declare specific data elements to U.S. Customs and Border Protection (CBP) to determine tariff applicability and ensure proper classification. These include:
- Country of smelt and cast for aluminum products
- Country of melt and pour for steel articles
- Aluminum and Steel content and valuation for composite goods (reported separately from non-aluminum and non-steel components)
- Country of origin for copper products, especially semi-finished and derivative goods
- Origin documentation such as mill certificates or supplier declarations
- HTSUS classification under Chapter 99 for the corresponding Section 232 applicability
Compliance for derivative articles can be particularly complex, as importers are required to separately declare the value and weight of the metal content for each item. Accurate reporting of these elements is essential to avoid elevated tariffs and to ensure timely customs clearance.
The Role of Suppliers in Compliance
While U.S. importers are ultimately responsible for reporting the required data elements, accurate compliance often depends on the cooperation of overseas suppliers. Suppliers must understand the specific reporting requirements and provide timely, verifiable documentation. Without this, importers risk misclassification, delayed shipments, or exposure to elevated tariffs, such as the 200% duty on aluminum with unknown origin.
Ensuring supplier awareness and alignment is therefore critical to maintaining compliance and avoiding costly enforcement actions.
Best Practices for Importer Compliance
To help mitigate compliance risks and avoid costly penalties or shipment delays, importers should:
- Engage suppliers as far upstream as possible to explain reporting obligations
- Provide clear documentation templates and data checklists
- Educate suppliers through briefings or translated materials
- Include compliance clauses in contracts
- Conduct regular audits to verify origin data
- Maintain clear communication and escalation channels for questions and updates
How Tradewin Can Help:
Tradewin’s global team delivers end-to-end compliance solutions for U.S. importers working with overseas suppliers who must provide origin and value breakdown data under Section 232. Our origin managed services complement U.S. import advisory support by helping companies implement Standard Operating Procedures (SOPs), define service-level agreements (SLAs), share best practices, conduct training in local languages, and collect data across time zones.
We also support clients with post-entry audits and periodic reviews to validate supplier data and ensure ongoing compliance. This integrated approach ensures suppliers understand their obligations and enables importers to maintain consistent, accurate reporting.
Contact Tradewin to discuss how our global team can support your trade compliance operations with tailored, end-to-end solutions.
