FAQs – Section 232 Steel and Aluminum

The Section 232 tariffs on steel and aluminum goods have started. Here is a list of the most frequently asked questions to help you navigate the new requirements.

When did the Section 232 tariffs on steel and aluminum start?

The tariffs were reimposed on March 12, 2025. The original Section 232 tariff action started in 2018.

What are the key changes?

Three key changes occurred when the Section 232 tariff action was reimposed:

• Aluminum tariffs increased from 10% to 25%
• All exclusions, including General Approved Exclusions (GAEs), Country-specific Exclusions, Absolute Quota, and Tariff Rate Quota, were eliminated. The only exceptions are granted Importer-Specific Exclusions shall remain effective until their expiration date or until the excluded product volume is imported, whichever occurs first.
• Two new lists of steel and aluminum derivatives have been added.

Which steel and aluminum products are impacted?

Very specific Harmonized Tariff Schedule of the U.S. (HTSUS) numbers are subject to the Section 232 tariffs. This includes:

• The original Section 232 lists of steel and steel derivatives and aluminum and aluminum derivatives.

• New steel derivatives
• New aluminum derivatives

Search the Original and New Lists

What type of additional information is required?

New Steel Derivatives in Chapter 73

• Country of Melt and Pour

New Steel Derivatives outside of Chapter 73

• Value of Steel Content
• Quantity of the Steel Content in Kilograms (kg)
• Country of Melt and Pour

New Aluminum Derivatives in Chapter 76

• Country of Smelt (Primary and Secondary) and Cast

New Aluminum Derivatives outside of Chapter 76

• Value of Aluminum Content
• Quantity of the Aluminum Content in Kilograms (kg)
• Country of Smelt (Primary and Secondary) and Cast

Is a mill certificate or statement of percentages required for derivatives?

Per Customs regulations, 19 CFR 141.89 – Additional information for certain classes of merchandise. Invoices for the following classes of merchandise, shall set forth the additional information specified:

Aluminum and alloys of aluminum classifiable under subheadings 7601.10.60, 7601.20.60, 7601.20.90, or 7602.00.00, HTSUS (T.D. 53092, 55977, 56143)—Statement of the percentages by weight of any metallic element contained in the article.

Iron or steel classifiable in Chapter 72 or headings 7301 to 7307, HTSUS (T.D. 53092, 55977)—Statement of the percentages by weight or carbon and any metallic elements contained in the articles, in the form of a mill analysis or mill test certificate.

For products classified outside of these classifications, a mill certificate and or statement of percentages is not required to be filed at the time of entry. U.S. Customs and Border Protection (CBP), however, can request the importer to provide a certificate of analysis. If you have one available, we recommend retaining a copy as a supporting document.

What if a derivative product is on the Section 232 list, but does not contain any steel or aluminum?

For products classified outside of Chapters 73 and 76, it must contain the associated metal to be assessed Section 232 duties.

We recommend having your supplier add to the invoice line information indicating the product “does not contain aluminum”, or “does not contain steel.”

What are the definitions for ‘Country of Smelt and Cast’?

Reference: CSMS# 55424218 – Guidance: Section 232 Aluminum Smelt and Cast Requirements

Primary Country of Smelt

The country where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.

Secondary Country of Smelt

The country where the second largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.

If Russia is not the country reported for the primary country of smelt, and any primary aluminum used in the manufacture of the product was smelted in Russia, report the ISO code for Russia as the secondary country of smelt.

Products of the U.S. are not covered by the countries of smelt and cast reporting requirements.  Until further notice, for products of the U.S., filers may report “N/A” for the countries of smelt, and U.S. for country of cast.

Country of Cast

The country where the aluminum (with or without alloying elements) was last liquified by heat and cast into a solid state. The final solid state can take the form of either a semi-finished product (slab, billets or ingots) or a finished aluminum product.

Products of the U.S. are not covered by the countries of smelt and cast reporting requirements.  Until further notice, for products of the U.S., filers may report “N/A” for the countries of smelt, and U.S. for country of cast.

What is the definition of ‘Country of Melt and Pour’?

Reference: CSMS# 62582900 – Guidance: Section 232 Melt and Pour Requirements

Country of melt and pour refers to the original location where the raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. The first solid state can take the form of either a semi-finished product (slab, billets, or ingots) or a finished steel mill product. The location of melt and pour is customarily identified on mill test certificates generated at each stage of the production process and maintained in the ordinary course of business.

Are there any exclusions from the Section 232 duties?

Yes.

Original Steel and Aluminum Lists

Importer-specific product exclusions for Section 232 duties that are active shall remain effective until their expiration date or until the excluded product volume is imported, whichever occurs first.

Derivatives of Steel or Iron

Products where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the U.S. are subject to 0% duty rate when using the additional HTSUS 9903.81.92

Aluminum Derivatives

Derivatives processed in another country from aluminum articles that were smelted and cast in the U.S. are subject to 0% duty rate when using the additional HTSUS 9903.85.09.

Is Aluminum from Russia subject to 200% duty?

Yes, the 200 percent duties on any aluminum products and derivative aluminum products subject to Section 232 that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, are still in effect.  These duties are to be applied on the entire value of the imported good.  Importers should continue to report HTS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products; subject to the 200 percent Russia aluminum duties.

Are Section 232 duties eligible for Drawback?

No drawback shall be available with respect to the duties imposed.

What’s the best way to communicate the additional information to the Customs Broker?

The additional information should be communicated clearly to the Customs Broker to ensure a correct customs entry. We recommend that suppliers add extra information to the commercial invoice.

How to report the ‘country of melt and pour’ when the product is subject to Section 232 derivative measures, but the importer does not know the country of melt and pour?

Per CBP FAQs, for derivative steel, filers can report OTH (Other) for the country of melt and pour.

How to report the ‘country of smelt and cast’ when the product is subject to Section 232 derivative measures, but the importer does not know the country of smelt and cast?

Per CBP FAQs, for derivative aluminum, the filer, as an interim solution, may report “RU” for Russia if the filer does not know the country of smelt or cast; and pay the 200 percent Russia aluminum duty pursuant to Presidential Proclamation 10522 (88 FR 13267, March 2, 2023). Also see CSMS # 64384496. Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual countr(ies) of smelt or cast. For a long-term solution, CBP is looking into other options for reporting an unknown country of smelt or cast, which will also require paying the 200 percent Russia aluminum duty. CBP will provide guidance through CSMS when more information is available.

For steel and aluminum derivatives subject to HTS 9903.85.08 and HTS 9903.81.91, is there a minimum amount of steel or aluminum content required in order to be subject to Section 232 duties?

Per CBP FAQs, there is no minimum amount of derivative steel or aluminum content provided for.

Can filers report a unit of measure of less than 1?

Yes, filers can report less than 1 and decimals only two values after the decimal i.e. 1.10 or .01.

How to determine the value of aluminum or steel content for derivative products outside of Chapter 76 or 73?

According to CBP FAQs, the value of the steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a.  Thus, the value of the steel/aluminum content is the total price paid or payable for that content, which is the total payment (direct or indirect, and exclusive of any costs, charges, or expenses incurred for transportation, insurance, and related services incident to the international shipment of the merchandise from the country of exportation to the country of importation) made/to be made for the steel/aluminum content by the buyer to, or for the benefit of, the seller of the steel/aluminum content.  Normally, this would be based on the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content. 

Let us know if you have any additional questions. Reach out to your local NNR contact.

Read More: Tariffs on All Steel and Aluminum Derivatives Start March 12