Non-Metal HTS Added to Section 232 Metals Trade Remedy Program
Trade Update • May 6, 2026
Key Points
- The U.S. Department of Commerce added new HTSUS provision 9903.82.01 for products that do not contain aluminum, steel, or copper under the Section 232 trade remedy program.
- Goods classified under 9903.82.01 are not subject to Section 232 duties because they are not aluminum, steel, copper, or derivative products.
- Importers previously used exemption 9903.82.03 for low-metal-content goods. The new provision now gives non-metal products a dedicated exemption classification.
- The update applies retroactively to entries filed on or after April 6, 2026. Some entries filed under 9903.82.03 may require amendments to reflect the new HTSUS provision.
- Importers should review affected products, update commodity databases, and coordinate with their Client Care Manager regarding post-entry corrections or exemption claims.
The U.S. Department of Commerce has announced a technical correction to Annex IV of the April 2 proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.”
As part of this correction, a new HTSUS provision—9903.82.01—has been established for:
“Articles provided for in subdivision (c) of U.S. Note 16 to this subchapter that do not contain any aluminum, steel, or copper.”
According to the Federal Register notice, these goods “do not contain any aluminum, steel, or copper because [they are] not an aluminum, steel, or copper article or one of their derivatives, and therefore, the duties imposed do not apply.”
What This Means for Importers
Prior to this update, products that did not contain aluminum, steel, or copper were commonly entered under exemption 9903.82.03, which applies to goods containing less than 15 percent aggregate metal by weight.
With the introduction of 9903.82.01, importers now have a dedicated HTSUS provision for goods that contain no aluminum, steel, or copper, eliminating the need to rely on the de minimis metal exemption in these cases.
Retroactive Effective Date
This change is retroactive to April 6, 2026. As a result:
- Entries filed on or after April 6, 2026
- That do not contain aluminum, steel, or copper
- And were entered under 9903.82.03 may require amendment to reflect the new exemption provision, 9903.82.01.
Next Steps
If you have parts or products that meet the criteria above, please contact your Client Care Manager to update your commodity‑level database and determine whether post‑entry corrections or amendments are required.
To support the claim process, we have provided the [Required Forms for Download]. If you wish to make this claim, please complete the forms and return them to your Client Care Manager, who can also assist with any questions about entry documentation or self‑certification determinations.
GHY will continue to monitor developments related to Section 232 trade remedies and provide timely guidance as the trade landscape evolves. Visit GHY Trade Updates for the latest compliance insights and regulatory 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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