Accurate Reporting of Section 232 Duties: A Vital Reminder for Steel & Aluminum Imports

In global trade, precision isn’t merely a best practice—it’s a compliance requirement. For importers handling steel and aluminum articles and their derivatives, the accurate reporting of Section 232 content and quantities under U.S. Customs and Border Protection (CBP) guidance remains critical.

Why This Matters

The stakes are high when it comes to the duties under Section 232 of the Trade Expansion Act of 1962 covering steel and aluminum articles. Importers must ensure correct content valuation, proper classification, and detailed origin reporting. Missteps not only expose your organisation to unexpected costs and penalties, but can also create reputational risk in a compliance-sensitive environment. CBP expects full accuracy from the trade community—including those working with global freight forwarders like Future Forwarding—to uphold the integrity of U.S. trade-remedy regimes and safeguard supply-chain transparency.

Key Reporting Requirements

1. Proper Reporting of Steel & Aluminum Content

For goods classified under Chapter 73 (steel) or Chapter 76 (aluminum) of the HTS, the Section 232 duty is assessed only on the value of the steel or aluminum content.
If the value of the steel/aluminum portion is unknown or is the same as the entered value, you must report the duty based on the entire entered value and do this on a single entry line.
If the steel/aluminum content value is less than the entered value, you must split the entry: one line for the non-steel/aluminum portion, one line for the steel/aluminum portion—using the correct HTS classifications and quantities.
Critically: do not duplicate quantities when splitting lines for content reporting.

2. Melt, Pour, Smelt & Cast Origin Reporting

For steel articles, importers must report the country of melt and pour using the ISO country code. For derivatives, report the ISO code of the country of melt, or use “OTH” when applicable.
For aluminum articles, you must report the primary country of smelt, secondary country of smelt, or most recent country of cast, using ISO codes. Filers must report a “Y” indicator for primary or secondary.
Aluminum manufactured solely from recycled aluminum must have underlying manufacturing documentation available upon request.

3. Foreign Trade Zone (FTZ) Entries

Steel and aluminum articles admitted into a U.S. FTZ must be granted “privileged foreign status” and reported under the correct HTS classification.
Smelt and cast origin-reporting rules apply to aluminum goods admitted into an FTZ and later withdrawn for consumption.

4. Duties for Aluminum from Russia

The 200 percent duty on aluminum products and derivative aluminum products from Russia remains in effect. These duties apply to the entire value of the imported good.

5. Application of Reciprocal Tariffs

When you separate non-steel/aluminum content on its own line, that portion is subject to the reciprocal tariffs under HTS 9903.01.25.
The steel/aluminum content that is subject to Section 232 duties is not subject to reciprocal tariffs under HTS 9903.01.33.

6. Reporting Entry Summary Lines with Multiple HTS Numbers

If an entry summary line lists multiple HTS numbers, you must ensure that duties are properly associated with the correct HTS numbers.
You cannot combine duties across several HTS numbers and report them under only one classification.

Tips for Staying Compliant

Validate content valuations — Work closely with your suppliers or internal teams to determine the steel or aluminum portion value early in the importing process.
Train entry-summary teams — Ensure your staff know when to split entry lines, how to select the correct HTS, and how to report melt / smelt / cast origin codes.
Leverage your forwarder or customs broker — A knowledgeable partner like Future Forwarding can help identify potential pitfalls ahead of time and ensure the correct handling, especially for complex goods or FTZ entries.
Document everything — Keep proof of supplier values, origin codes, manufacturing documentation (especially for recycled aluminum), and entry-summary line logic. In the event of a CBP review, meticulous documentation strengthens your position.
Review shipments from high-risk jurisdictions — Especially for aluminum from Russia or goods requiring FTZ treatment.
Stay abreast of CSMS updates — CBP regularly issues clarifications, and maintaining proactive monitoring of CSMS guidance reduces surprise exposure.

Accurate reporting of Section 232 duties for steel and aluminum isn’t optional—it’s foundational. For importers and their logistics partners, the detailed obligations around content values, origin reporting, FTZ treatment, and separate handling of non-steel/aluminum content are non-negotiable. Future Forwarding remains committed to providing expert guidance and operational support to help you navigate these requirements with confidence and precision.