CBP has updated its FAQs for Section 232 duties for aluminum and steel
Washington, DC, 21 MAR, 2025 – CBP has updated its FAQs for Section 232 duties for aluminum and steel.
Please refer to the link below.
https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel/faqs
CBP has provided specific guidance in the FAQ's for how to value the steel and/or aluminum content for derivative items NOT classified in Chapter 73 or 76 (the HS codes that start with anything other than 73 or 76) that are on the Steel or Aluminum lists.
Here is the snapshot of this question from the FAQ's
How to determine the value of aluminum or steel content for derivative products outside of CH. 76 or 73?
The value of the steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a. Thus, the value of the steel/aluminum content is the total price paid or payable for that content, which is the total payment (direct or indirect, and exclusive of any costs, charges, or expenses incurred for transportation, insurance, and related services incident to the international shipment of the merchandise from the country of exportation to the country of importation) made/to be made for the steel/aluminum content by the buyer to, or for the benefit of, the seller of the steel/aluminum content. Normally, this would be based on the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content.
Also of important note, when an importer does not know the country of smelt and cast for aluminum, CBP has instructed the following:
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?
For derivative aluminum, the filer, as an interim solution, may report "RU" for Russia if the filer does not know the country of smelt or cast; and pay the 200 percent Russia aluminum duty pursuant to Presidential Proclamation 10522 (88 FR 13267, March 2, 2023). Also see CSMS # 64384496. Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual countr(ies) of smelt or cast. For a long-term solution, CBP is looking into other options for reporting an unknown country of smelt or cast, which will also require paying the 200 percent Russia aluminum duty. CBP will provide guidance through CSMS when more information is available.
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