U.S. Customs and Border Protection (CBP) has issued new guidance regarding technical corrections to Section 232 duties on imports of aluminum, steel, copper, and derivative products under Presidential Proclamation 11021.

The update includes the creation of a new HTSUS classification for certain products that do not contain aluminum, steel, or copper, along with clarification regarding treatment of certain U.K.-origin steel articles produced by Tata Steel UK with a Netherlands melt and pour designation.

Key Updates courtesy of KWE USA Compliance:

• New HTSUS classification 9903.82.01 established for qualifying articles containing no aluminum, steel, or copper, with a 0% additional duty rate
• CBP confirmed certain U.K.-origin steel articles produced by Tata Steel UK with Netherlands melt and pour designation remain eligible for reduced Section 232 tariff treatment through January 1, 2028
• Changes apply retroactively to applicable goods entered or withdrawn from warehouse for consumption on or after April 6, 2026

To assist customers in evaluating potential Section 232 applicability and supporting entry filing requirements, KWE USA Compliance has also prepared an internal Section 232 Metals Importer Questionnaire covering:

• Metal content declarations
• Country of melt and pour / smelt and cast
• Russian-origin determinations
• HTS Chapter 99 selection guidance
• Applicable Section 232 classifications and duty scenarios

Please refer to the attached documents for additional details:

• CBP CSMS #68554727 Guidance
• Metals HTS LIST 050426.pdf
• 2026-04-06 KWE Section 232 Metal Importer Questionnaire Fillable V2.pdf

If you have any questions regarding these updates or their potential impact on your shipments, please contact your KWE representative.

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