Section 232 steel & aluminium

What the programme looks like now

Section 232 lets the President adjust imports that Commerce has found to threaten national security. On steel and aluminium the current programme started in 2018, was rebuilt in February 2025 and reset again in June 2025 at 50% on both metals. The history matters less than three structural facts, because those three decide how your entry is built.

1. There are no country exemptions left. The arrangements with individual trading partners, and the quotas that came with them, were terminated in March 2025.
2. The product exclusion process is closed to new requests. What replaced it runs the other way.
3. An inclusions process adds derivative articles to the annex on a fixed calendar. A part you filed last year at its ordinary rate can be inside the annex this year without anything about the part changing.

That third point is the one that catches importers, so we watch the Federal Register notices against the subheadings you actually import. You hear about an inclusion before its effective date, not on an arrival notice.

Melt and pour, smelt and cast

Origin for Section 232 is not the ordinary origin rule and it is not where the article was finished. For steel it is where the metal was melted and poured, meaning where raw steel was first produced in a solid state, regardless of where it was later rolled, cut, welded, galvanised or machined. A fabricator in one country working coil melted in another is declaring the melting country.

Aluminium needs three fields rather than one: the primary country of smelt, the secondary country of smelt, and the country of most recent cast. The evidence for all of this is the mill test certificate. If a certificate names a mill but not a country, we will go back for a better one before filing, because the alternative is a declaration we cannot support if CBP asks. And on aluminium, reporting a smelt or cast country as unknown draws the 200% Russian rate, so "the supplier will not tell us" is an expensive answer.

The content split

On raw metal the entered value is all metal and the 232 line is simple. On a derivative it is not. The duty attaches to the value of the steel or aluminium content, and the remaining value of the article is dutiable at its ordinary rate. So one invoice line becomes two entry lines: the metal content under the Chapter 99 heading, the balance under the Chapter 73, 76, 84 or 87 subheading where the article belongs.

If you cannot state the metal content value, the 232 rate applies to the entire entered value of the article. Getting that figure out of a supplier is the real work on these files, and it is work we would rather do three weeks before arrival than at the terminal.

An article containing both steel and aluminium can carry both duties, each on its own content value. That is not double counting, it is two separate programmes reaching two separate materials in the same part.

Stacking, and what 232 does not do

• Where an article is covered by the Section 232 action on automobiles and automobile parts, it is not additionally charged the steel and aluminium 232. There is a published order of precedence and it is applied line by line, not shipment by shipment. See auto parts and vehicles.
• Section 301 China duties sit on top of Section 232, and so do AD/CVD cash deposits. These are different instruments, not alternatives to each other. Section 301 in brief.
• Section 232 duties are not eligible for drawback. Section 301 duties are. If your programme depends on recovering duty on goods that leave again, this changes the arithmetic materially.
• Goods subject to 232 have to be admitted to a foreign trade zone in privileged foreign status. Admit them in non-privileged status and the position cannot be recovered later.

What we need from you

• Mill test certificates naming the producing mill and the country.
• Steel: country of melt and pour, per line.
• Aluminium: primary smelt, secondary smelt and most recent cast, per line.
• Metal content value per article on derivatives, ideally as a standing figure held against the part number rather than a one-time estimate.
• Weight in kilograms, which the Chapter 99 line reports.

For a repeat programme we hold that data as a part table, so the second container is a reconciliation rather than a rebuild, and a change in any field shows up as an exception instead of slipping through. If your commodity is broader than the metal itself, the metals page covers classification and AD/CVD scope in more depth.