U.S. importers of steel, aluminum, and certain derivative products continue to face heightened scrutiny under Section 232. While the tariffs themselves are well established, recent clarification from U.S. Customs and Border Protection (CBP)—particularly from the Base Metals Center of Excellence and Expertise (CEE)—has reinforced how steel and aluminum content must be valued and reported for duty purposes.
Recent clarification from U.S. Customs and Border Protection (CBP), including guidance from the Base Metals Center of Excellence and Expertise (CEE), has reinforced how steel and aluminum content must be valued and reported for Section 232 duty purposes, with important implications for importer compliance and reasonable care
What Counts as Steel or Aluminum Content
For Section 232 purposes, references to steel and aluminum include their respective alloys. CBP has made clear that importers may not break down an article’s chemistry to remove the value of alloying elements. Alloying elements are considered part of the steel or aluminum and must remain included in the dutiable value.
Only legitimately separable non‑steel or non‑aluminum components—such as glass, electronics, or other distinct parts—may be excluded from Section 232 value. Manufacturing, machining, fabrication, coatings, labor, overhead, and profit are not considered non‑steel or non-aluminum components and generally may not be deducted.Chapter 72 Steel: Fully Subject to Section 232
Steel articles classified in HTS Chapter 72 are treated as 100 percent steel for Section 232 purposes. As a result, Section 232 duties are assessed on the full entered value of the article. There is no allowance to back out production‑related costs, including labor, coating, or overhead. CBP’s position is explicit: Chapter 72 steel is fully dutiable regardless of downstream processing or value added.
Chapters 73, 76, and Other Classifications
For steel articles of Chapter 73, aluminum articles of Chapter 76, and articles classified outside Chapter 72, CBP applies a content‑based approach.
If an article is entirely steel or aluminum, Section 232 duties apply to the entire entered value, with no deductions for manufacturing or processing costs.
If an article contains legitimate non‑steel or non-aluminum components, Section 232 duties apply only to the steel or aluminum content. In these cases, the steel or aluminum value is determined by subtracting the importer’s cost of the non‑steel or non-aluminum components from the total entered value. CBP has emphasized that non‑steel and non-aluminum content refers only to distinct components—not to fabrication or labor.
How CBP Expects Value to Be Determined
CBP has stated that the value of steel or aluminum content should be based on what the importer paid—specifically, the invoice paid by the buyer to, or for the benefit of, the seller of the steel or aluminum content.
In practice, CBP expects importers to start with the entered value of the finished article, subtract the cost of legitimate non‑steel and non-aluminum components, and treat the remainder as the Section 232 metal value. Where costs relate to both steel or aluminum and non-steel or non-aluminum, a reasonable and supportable allocation methodology may be acceptable, but the burden of proof remains with the importer.
When Separation Is Not Allowed
Section 232 duties must be assessed on the full entered value when the steel or aluminum content cannot be reliably determined, when an article contains a mix of U.S. and foreign steel or aluminum, or when the article is not exclusively made from U.S. melted‑and‑poured steel or U.S. smelted‑and‑cast aluminum. Importantly, Section 232 exemptions tied to U.S. origin are all‑or‑nothing provisions—partial claims are not permitted.
Additional Considerations: Copper and Iron
CBP has indicated that copper and copper alloys, including brass and bronze, follow the same valuation principles as steel and aluminum for Section 232 purposes. Chemistry‑based breakdowns are not permitted. Treatment of iron now varies based on tariff classification and effective date, particularly for derivative articles, making accurate classification critical.
How Tradewin Can Help
Section 232 valuation remains a high‑risk area, especially where partial value claims, origin determinations, or historical filings are involved. Tradewin supports importers with origin and melt‑and‑pour or smelt‑and‑cast assessments, development of defensible valuation methodologies, and review of entries for potential misreporting or overpayment. We also assist with prior disclosures and protests for previously incorrect entries.
If you have questions about your current Section 232 filings or concerns about how steel or aluminum content has been reported in the past, Tradewin’s trade advisory team can help you assess risk and strengthen compliance going forward. We’re here to help.
