Steel, aluminium & metals

The arithmetic is the risk

Every line on a metal entry carries a Chapter 72 to 76 classification, an origin of melt and pour or of smelt and cast, a metal content value, and a possible antidumping case number. Each of those four moves the duty independently of the others. Classify the article correctly and report the origin field wrong and you still pay the wrong number, either overpaying now or owing the difference with interest three years later when the entry liquidates.

That is why we build these entries against a part table rather than keying an invoice. Classification, content value and origin are held per part number, the shipment reconciles against the table, and new part numbers are flagged for classification before they arrive rather than on the invoice we are trying to file.

Section 232 as it stands in 2026

The country arrangements, tariff-rate quotas and absolute quotas that used to govern steel and aluminium were terminated in March 2025, and the product exclusion process closed to new requests at the same time. In June 2025 the rate on both metals moved to 50% (the United Kingdom has been handled under its own separate arrangement). What replaced exclusions is an inclusions process: Commerce adds downstream derivative articles to the annex on a fixed calendar, and the list only grows.

The practical effect is that goods you used to file on one line now take two. The steel or aluminium content goes on a Chapter 99 line at the 232 rate, and the rest of the article stays at its ordinary rate. If the metal content value is not declared, CBP applies the 232 rate to the entire entered value of the article. On a 50% tariff, that gap is usually the largest single number on the entry, and it is almost never a judgement call. It is a figure missing from a mill certificate. The full mechanics are on the Section 232 page.

Copper came into the programme in August 2025. Semi-finished copper products and copper-intensive derivatives carry their own 232 rate on the same content logic. If you bring in brass fittings, copper tube, busbar or wound components, treat the question as live until we have checked the annex against your subheadings.

AD/CVD is decided by scope, not by HTS number

The tariff numbers printed in an antidumping or countervailing order are there for the convenience of CBP. The scope paragraph is what governs. A product can sit squarely inside a scope under a subheading the order never mentions, and it can share a subheading with covered goods and be entirely outside the order. We read the scope. Where the answer is genuinely ambiguous we say so, and we tell you what a scope ruling from Commerce costs in months before you decide to gamble instead.

Two mechanics do most of the damage here. Cash deposit rates change with annual administrative reviews, and the reviewed rate can apply to entries already made, so a bill plus interest arrives long after the goods were sold. And an evasion allegation under the Enforce and Protect Act suspends liquidation and applies rates retroactively from ninety days before the investigation started, whether or not you knew anything about your supplier. Background reading: antidumping and countervailing duties.

What actually goes wrong

• A mill test certificate that names a mill but not a country, or an aluminium invoice with no primary smelt, secondary smelt and most recent cast. Aluminium whose smelt and cast countries are reported as unknown is treated as Russian, and the Russian rate is 200%.
• One classification applied down a whole invoice because the lines look alike. Fittings, flanges, tube, bar and plate are different subheadings with different AD/CVD exposure.
• Metal content given as a percentage of weight when the entry needs a value in dollars.
• A supplier switching mills mid-order without telling anyone. That changes origin, which changes both the 232 position and the AD/CVD position on the same shipment.
• Admission to a foreign trade zone in non-privileged foreign status. Goods subject to 232 have to go in as privileged foreign, and the status cannot be recovered afterwards.

What we need from you

• Commercial invoice with per-line description, grade or alloy, form, quantity in kilograms and unit value.
• Mill test certificates matched to the lines they cover.
• Country of melt and pour for steel. Primary smelt, secondary smelt and most recent cast for aluminium, which the tariff itself spells aluminum in the Chapter 76 heading.
• Metal content value where the article is a derivative rather than raw metal.
• Any scope ruling, exclusion or supplier certification you are relying on, in writing.

One planning point before you build a programme around recovery: Section 232 duties are not eligible for drawback, while Section 301 duties are. If the metal is going back out again, the number you get back may be a good deal smaller than the number you paid.