U.S. Duties on Steel and Aluminum Derivatives – Key Reporting and Compliance Updates [Updated]

Trade Update • March 27, 2025

Section 232 Frequently Asked Questions Section has been updated to reflect reporting guidance on the country of smelt and case if unknown.

ver the past few weeks, numerous Trade Actions have been implemented, requiring the assessment of additional duties on goods imported into the U.S. These changes have significantly impacted the trade community.

At GHY, we are working diligently with our clients, our vendors, as well as behind the scenes to ensure the seamless flow of shipments across the border. The area with the largest impact to date is the assessment of Section 232 duties on steel and aluminum derivative products.

To help you comply with these new tariff regulations and mitigate processing delays, please ensure that the following information is included with your shipping documents – either at the invoice line level or using our supplied worksheet, available below:

Worksheets: Section 232 Steel and Aluminum Derivatives Content – GHY-USA

Required Information for Shipping Documents

1. Product Description

• Clearly specify the material composition of each item, SKU, or part.
• This is especially important for derivative articles classified outside Chapters 73 or 76 that do not contain steel or aluminum.

2. Country of Melt/Pour & Smelt/Cast

For goods containing steel or aluminum, indicate:

• The country of melt/pour for steel articles.
• The country of smelt/cast for aluminum articles.

3. Derivative Content

For derivative articles subject to Section 232 duties but NOT classified in Chapter 73 or Chapter 76, duties may be assessed based on the value of the steel and/or aluminum content.

To apply duty to the content only, the following information is required:

• • Provide a breakout of the value for the non-steel/aluminum content and the steel/aluminum content.
  • Include the weight (in KG) of the steel and/or aluminum content.

Section 232 Frequently Asked Questions
For full details on Section 232 duties, including how the value applied to derivative content is determined and the reporting requirements for country of melt/pour and smelt/cast, please refer to CBP’S updated –
Section 232 Tariffs on Steel and Aluminum Frequently Asked Questions

• CBP has clarified that if the country of smelt/cast for aluminum products is unknown, the interim solution is to report Russia as the country of smelt/cast, and the goods will be subject to 200% duty.
• Further CBP guidance on how to report “unknown” as the country of smelt/cast is pending, however those goods will still be subject to 200% duty.

Update
Q: How to report the country of smelt and cast when the product is subject to Section 232 derivative measures, but the importer – does not know the country of smelt and cast?
A: For derivative aluminum, the filer, as an interim solution, may report any country other than the United States if the filer does not know the country of smelt or cast. Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual countries) of smelt or cast. For a long-term solution, CBP is looking into other options for reporting an unknown country of smelt or cast. CBP will provide guidance through CSMS when more information is available.

Customs Surety Bonds

The implementation of new tariffs by the governments of the United States and Canada will significantly increase duty payments for importers, directly affecting their customs surety obligations. Understanding these obligations is essential to prevent disruptions in the import process.

Customs Surety Requirements in Canada

Under new framework of the CBSA Assessment and Revenue Management (CARM), all importers must soon secure their own customs bond to cover duty payments. To facilitate this transition, importers have a 180-day grace period ending on April 19, 2025, to secure a bond.

Given the introduction of a 25% tariff on U.S.-origin goods, duty payments will increase significantly. Canadian importers should review their current surety arrangements to ensure compliance. If an importer’s surety does not cover the required duty payment at the time of import, CBSA may detain the shipment until sufficient surety is provided or duties are paid in full.

Customs Surety Requirements in the U.S.

The imposition of universal tariffs on goods from Canada, Mexico, and China requires U.S. bondholders to reassess the sufficiency of their customs bonds. If an importer’s bond does not cover the value of duties at the time of import, U.S. Customs and Border Protection (CBP) may issue a written notification requiring an increase in bond coverage.

Importers generally have 30 days to adjust their surety. Failure to do so may result in bond termination, leaving the importer without coverage for customs duties. In such cases, goods will be held at the border until the importer secures adequate surety or pays the duties in full.

The information presented is general in nature, and is not intended to constitute legal advice with respect to any event or occurrence, and may not be considered as such.​​ Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.​ Due to the complexity of Customs Regulations, valuations are based on information currently available and should not be considered binding, we recommend obtaining National Customs Rulings in areas of uncertainty.​

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.

Please contact your Client Care Manager or our Global Trade Services Team gts@ghy.com, or call +1 (800) 667-0771.