232 & 301

  • Aluminum in Paint Cans – 232 Tariff

    Question: After the latest 232 steel/aluminum update, is paint is exempt and the aluminum is still dutiable if the weight is greater than 15% of the total weight of the good or is 3209 and 3208 now completely exempt? Answer 1: If the HTS for paint has been removed from the derivative 232 list, then […]

  • Sec 232 & Packaging

    Question: We have a machine that is imported in a steel framework for handling. It’s not reusable. Does this frame need to be included in the Sec 232 calculations although not a part of the machine, not reusable once “uncrated”? Answer 1: It is my understanding that “packaging” is a part of the PPV value […]

  • S232 Template for Cost Breakdown

    Question: Does anyone have a spreadsheet or template that we can provide to our overseas manufacturers for purposes of breaking out/itemizingthe different costs associated with S232 reporting? Answer 1: Attached is the file we use that was provided by one of our brokers. https://www.icpainc.org/wp-content/uploads/2026/03/Sec-232-Template.xlsx

  • Steel Aluminum Copper 232

    Question: I am looking for 3 accurate up to date HTS lists for steel, aluminum and copperIs there any place or anyone that has these 3 lists that show the 232 HTS codes for steel –Aluminum — Copper  Asked by: Laura Callesano – Lcallesano@4implus.com Answer 1: Search for CBP Cargo Systems Messaging Servicehttps://www.cbp.gov/trade/automated/cargo-systems-messaging-serviceGo to the […]

  • Section 232 and Temporary Imports

    Question: Because TIB’s avoid an “entry for consumption,” they are exempt from Section 232, right?(Not exempt from potential duty liability, though.  Must post a bond for the entire amount, inc. 232)? Answer 1: Yes, but I am not certain that “exempt” is the correct wording. See CBP’s FAQ’s on section 232 duties.  https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel-faqs   Answered by: […]

  • Section 232 Derivatives

    Question: Is this accurate for Section 232 derivatives HTS numbers: Steel:  We are permitted to enter Unknown for country of melt and pour provided we’re willing to pay 50% of the entire value of the good. Aluminum:  We are permitted to enter Unknown for country of smelt and cast provided we’re willing to pay 200% […]

  • Extended Section 301 ’24 Expanded List 2 25%

    Question: Has anyone heard of stacking Section 301 Tariffs with other 301 tariffs? If so, has US Customs provided guidance outside of the stacking guidance on 232.   Our article of China, product is listed on the good old 4A list at 7.5% (9903.88.15),  but also on the 301 25% extended list (9903.91.06 effective Jan 1, […]

  • Section 232 vs. Iron Content

    Question: Just curious if the vast and unpaid research department known as ICPA members has an opinion on this question. And, of course, what is that opinion?When an imported item is classified with an HTS subject to 232 duties based on the steel content, and the item has no steel content, but has iron content, […]

  • Pump Bottles

    Question: We import pump bottles which are filled with hair products and cosmetics.  Do we need to break out the cost and % of steel of the spring in the pump on the commercial invoice?Our broker is telling us no; we don’t need to but would prefer to confirm with the group.We import the pumps […]

  • Proposed Sect 232 Inclusions

    Question: Today, Oct 7, the next round of Sect 232 Inclusion requests was published.  Is there a presumption of approval, or of denial? Answer 1: Based off of the August list, it’s a presumption of approval. The only items denied on that list were those that had other open AD/CVD or 232 investigations into the […]

  • Sec 232 Derivatives + Reciprocal Tariffs

    Question: We have a derivative product that is subject to the aluminum Sec 232 tariffs. As of the June 3rd announcement, the non-metal content is no longer exempt from reciprocal tariffs, and the importer may split the metal and non-metal content into two lines.If the importer cannot compliantly split the content into two lines because […]

  • Copper/aluminum/steel value calculations

    Question: CBP has published: The value of the copper/steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement The value of the XXX content is the total price paid or payable for that content, which is: The total payment made/to be made for the copper content by the buyer to, […]