Customer Advisory: U.S. Compliance Advisory

Summary of U.S. Customs and Border Protection (CBP) Guidance on Section 232 “Content Value”

The CBP Base Metals Center clarifies how the Section 232 duty (under Section 232 of the Trade Expansion Act of 1962) is calculated—specifically how to separate non-steel/aluminum/copper content value.

1. Steel Articles of Chapter 72

• 100% Steel Value: Articles of Chapter 72 are treated as 100% steel.
• Duty Assessment: Section 232 duty is assessed on the full entered value of the article.
• No Subtractions: Costs for manufacturing, labor, coating, etc. are not subtracted.

2. Articles of Chapter 73, Chapter 76, and Elsewhere (Not Chapter 72)

• Wholly Steel/Aluminum: If the article is 100% steel or 100% aluminum, the duty is assessed on the full entered value. No subtractions are allowed for costs like manufacturing, labor, or coating.
• Non-Wholly Steel/Aluminum (Mixed Articles): If the article contains non-steel/aluminum parts or components, the Section 232 duty is assessed only on the steel/aluminum content.
  • Value Basis: The steel/aluminum content value is what the importer paid for that content, calculated as: Entered Value minus Cost of the non-steel/aluminum part/component
  • What is NOT Subtracted: “Non-steel/aluminum content” does not refer to costs for fabrication, machining, labor, coating, paint, lacquer, or other surface treatments (e.g., galvanizing, anodizing). These costs are considered integral and cannot be deducted.
  • Undeterminable Value: If the steel/aluminum content value cannot be determined, the duty must be reported using the total entered value on a single entry summary line.
  • Apportionment: Costs attributable to both (e.g., packaging) should be apportioned between the content subject to duty and the content not subject to duty.

3. Copper and Its Alloys

• Treated the Same: Copper and its alloys (e.g., brass) are treated the same as steel and aluminum alloys and are subject to Section 232 duty.
• No Chemical Breakdown: The chemistry of the imported article is not broken down to calculate a copper-only value; the value of alloying elements is not deducted.

4. Documentation

• Importers must have “documentation sufficient to support the importer’s claimed steel/aluminum content value” if CBP requests it.

 The core principle is that manufacturing, labor, and surface treatment costs are not deductible when determining the content value for Section 232 duty, even for mixed articles. Subtractions are only allowed for the cost of a separate, non-base-metal part or component.

STAY INFORMED – ONE FORWARDER, ONE BROKER = OVERALL COMPLIANCE!

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