Guidance on U.S. Content Assessment for Section 232 Steel, Aluminum, and Copper Tariffs
Published Oct. 13, 2026
Key Points
- Commerce issued guidance to CBP on assessing U.S. content for products from Canada and Mexico that qualify for preferential tariff treatment under USMCA.
- The guidance implements clause (2)(d) of Presidential Proclamation 11032, issued June 1, 2026, which addresses Section 232 tariffs on steel, aluminum, and copper.
- U.S. content means the value attributable to parts wholly obtained, entirely produced, or substantially transformed in the U.S.
- U.S. content also includes the value attributable to U.S.-melted and poured steel, U.S.-smelted and cast aluminum, and U.S.-smelted and cast copper, to the extent not already accounted for.
- Questions about applying the notice to specific products may be directed to CBP.
The
Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued guidance to U.S. Customs and Border Protection (CBP) on assessing “U.S. content” for tariff purposes. The guidance applies to products from Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) and implements clause (2)(d) of Presidential Proclamation 11032, which modifies tariffs on aluminum, steel, and copper imports.
As of this writing, the notice has not yet appeared in the Federal Register, although publication was scheduled for October 14, 2026. You can review the unpublished PDF version for details.
Definition of U.S. Content Under Proclamation 11032
According to the Department of Commerce, “U.S. content” means:
- The value of the product attributable to parts wholly obtained, entirely produced, or substantially transformed in the United States.
- To the extent not already accounted for in the first component, the value of the product attributable to steel melted and poured in the United States, aluminum smelted and cast in the United States, and/or copper smelted and cast in the United States.
Effective Date
The guidance takes effect for products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on the date of publication in the Federal Register, October 14, 2026.
Important Importer Considerations
Importers should work with their customs brokers to review product valuations, verify U.S.-content calculations, confirm USMCA eligibility, and determine how the guidance affects applicable Section 232 tariffs. GHY will provide updates if Commerce issues any further guidance or changes to the U.S.-content assessment requirements.
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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