Back to Trade Updates

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

Trade Update • Feb. 19, 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.
us-steel-aluminum-derivates

U​​​​​​​.S. Customs and Border Protection (CBP), through its Base Metals Center of Excellence and Expertise, has recently circulated updated 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.

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.

Subscribe!

Stay in the loop, stay compliant! Get weekly or daily insights into all things trade and event invites, delivered right to your inbox.

.