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CBP Base Metals Center – Guidance on Section 232 Content Reporting (Updated)

Published Feb. 19, 2026 | Updated March 24, 2026

Key Points

  • CBP has issued updated guidance on how it is currently interpreting and applying Section 232 duty assessments for steel, aluminum, and certain derivative products.
  • Valuation for Section 232 duties remains based primarily on the entered value of the imported article or, in limited cases, on the value of the metal content.
  • Certain costs, including fabrication, labor, or surface treatments, are considered part of the finished article and not separately deductible.
  • Importers must maintain sufficient documentation to support declared values in case of CBP review or requests for substantiation.
  • The value of U.S. steel or aluminum content may not be separated from foreign content in mixed-origin articles.
  • Latest Update: CEE issued informal guidance on March 15, 2026, clarifying its position on Section 232 content value for steel, aluminum, copper, and iron, including derivative articles and containers of non-metal products.
us-steel-aluminum-derivates

U​​​​​​​​​​.S. Customs and Border Protection (CBP), through its Base Metals Center of Excellence and Expertise, has released its updated informal guidance regarding how CBP is currently interpreting and applying Section 232 duty assessment for steel, aluminum, and certain derivative products.

This communication reflects CBP’s current position and understanding although CBP Headquarters has not yet issued formal or binding guidance.

Guidance

The guidance reiterates CBP’s approach to assessing Section 232 duties based on the entered value of the imported article or, in limited circumstances, the value of the steel or aluminum content contained within the article. CBP emphasizes that valuation must align with existing customs valuation principles and that certain costs (such as fabrication, labor, or surface treatments) are considered part of the finished article and are not separately deductible.

Importers should maintain documentation sufficient to support the declared values should CBP request additional information to substantiate the data reported at the time of entry.

CBP also notes for articles composed of US steel or aluminum as well as foreign steel or aluminum, the value of the US steel or aluminum content cannot be broken out.

Latest Update: Base Metal Center Informal Guidance (March 15, 2026)

The Base Metals Center of Excellence and Expertise has issued updated informal guidance clarifying Section 232 derivative reporting for steel, aluminum, copper, and iron.

Steel and Aluminum

  • Includes all alloys – breaking down the chemistry to remove alloying elements to arrive at steel or aluminum content is not allowed.
  • Costs attributable to both steel/aluminum content and non–content (labor, overhead, profit, packaging, etc.) may be apportioned based on a value ratio
  • Non-steel or aluminum articles of an HTS flagged for Section 232 (e.g., perfume, lotion, beer) the article’s container is subject if made of steel or aluminum. For example, beer classified 2203.00.0060 the Section 232 duty is assessed based on the cost of the aluminum can.

Copper

  • Treated the same as steel and aluminum

Iron

  • Articles classified in Chapter 72, 8708.10.30 and 8708.29.21 containing iron are subject to Section 232 duty
  • March 12 – June 3, 2025: Articles and parts classified in Chapter 73 containing iron are subject to Section 232 duty
  • Effective June 4, 2025: Articles and parts classified in Chapter 73 containing iron are no longer subject to Section 232 duty

Importer Discretion

This guidance represents CBP’s current interpretation only. Importers of record remain responsible for determining how information is reported on entry filings, based on their specific facts and circumstances and in compliance with CBP regulations.

GHY encourages importers to closely monitor official communications for any formal or changes, including:

Please note: This update is provided for general informational purposes only and should not be construed as legal advice or binding instruction. Importers are encouraged to rely on official CBP publications, such as CSMS notices and published rulings, for formal guidance and future updates.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.

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