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Guidance on U.S. Copper and Derivative Import Duties

Trade Update • July 31, 2025

copper-us-imports

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mporters of copper and copper derivative products should be aware of significant upcoming changes from U.S. Customs and Border Protection (CBP). Starting August 1, 2025, new Section 232 duties will be enforced under the guidance titled Adjusting Imports of Copper into the United States and referenced in CSMS #65794272 with comprehensive details outlined previously in U.S. Copper Imports Subject to 50% Tariff – Effective Aug. 1.

What’s Changing

Under the new guidance:

  • HTSUS 9903.78.01 imposes a 50% ad valorem duty on the copper content of semi-finished copper products and intensive copper derivative products, from all countries.
  • HTSUS 9903.78.02 applies a 0% duty on:
  • The non-copper content of such products.
    • Goods under the subject classifications that contain no copper.

Entry Filing Instructions

Importers must:

  • The value of the copper content should be determined in accordance with the Customs Valuation Agreement, which would be the total price paid or payable for the content portion of the goods sold. If the goods have not been sold, the Customs valuation methods hierarchy is to be followed.
  • Maintain documentation (e.g., invoices, bills of materials) to support declared copper values.
  • If documentation is insufficient, CBP may assess duties based on the entire value of the goods.

For imported articles composed only of copper, the dutiable value of the copper content is the total entered value, on only one entry summary line. 

If the value of the copper content cannot be determined, then report the duty based on the total entered value, on only one entry summary line.

Additional Notes

  • No drawback is available for these duties.
  • Goods entering Foreign Trade Zones must be admitted under privileged foreign status.
  • Products subject to both auto parts and copper duties will only be assessed under the auto parts provision.
  • The IEEPA reciprocal tariff exception (HTSUS 9903.01.33) may apply in certain cases.

Compliance & Potential Processing Delays 

Failure to provide all the required data elements with the release documentation may result in processing delays, up to the holding of shipments.   

  • Failure to provide copper content breakout for qualifying derivative products → 50% duty may be assessed on the full value. 

We encourage you to utilize the ITS client portal to monitor your entry reports and identify shipments of subject derivative products where the value of the copper does not constitute 100% of the part number’s total value. 

Adjustments & Post-Entry Modifications 

If the derivative content breakout is not included at the time of release, you may still provide the information to GHY post release.  Note that the rework of entries may be assessed additional filing fees or post entry fees accordingly. 

  • If received within 72 hours of release (excluding weekends) → GHY will attempt to update the entry before duties are paid. 
  • If received after 72 hours of release → A Post Summary Correction may be required, and a refund of duty paid may be requested from CBP.  

Ongoing Changes & Future Impact 

The current list of copper derivative products subject to Section 232 duties is not static. The U.S. Department of Commerce is developing a process to add additional products to the list. 

  • If your product is not currently impacted, it may become subject to duty in the coming weeks or months. 

GHY USA is actively adjusting our processes to align with new reporting requirements, ensuring that your duties to U.S. CBP are calculated accurately and remain compliant with evolving policies. Any additional duties and related processing fees will be reflected in your subsequent invoices from GHY USA.

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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