Question: My understanding of the 6/1/2026 232 changes are as follows:If an item is 85% or more US steel content, the item is considered COO US and subject to a 10% tariff rate.Does this mean we’re throwing out substantial transformation?If I ship US steel to MX to have it processed, and the item coming up […]
Question: When importing product subject to either the steel or aluminum tariff, specifically for derivative products, is there risk in reporting “Unknown” for the countries of melt and pour if the countries cannot be determined? Additionally, as the importer are you requesting a document such as the steel mill certificate on all imports subject to […]
Question: We are still getting errors via CAPE. The big one for us is “GOODS VALUE AMOUNT MUST BE REPORTED ON THE CH 1-97” and am I am not sure how to resolve.We import kits that require two lines for reporting and one of the lines will have zero duty. Is this something we are […]
Question: I asked the Trade Remedy team if the 95% threshold for US or UK metal was 95% of the weight or 95% of the value and they responded “95% of the content of the article.”(The 15% rule is explicitly weight but the 95% one is vaguer) “Of the content.” How do you interpret that? Answer […]
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 […]
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 […]
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
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 […]
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: […]
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% […]
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, […]
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, […]
