Question: Hello ICPA Community, If a part subject to Section 232 tariff and contains US melt/pour and non-US melt/pour steel content, how is transaction value apportioned to the US and non-US melt/pour: by weight, by value of raw material apportioned with overhead, labor, etc. or any other methodology exist out there? In a simple scenario, […]
Question: What are your thoughts on preparing a fallback estimation technique for section 232? I’m thinking we take some worst-case assumptions that product weight = steel weight, then use a high market price cost estimation. At least if it’s worst-case assumptions, it would be defensible. I’m just thinking that even if we use that it […]
Question: I’m looking to confirm whether CBP will consider the Country of Diffusion or Country of Origin for semiconductors when applying Section 232 tariffs. Any advice or guidance is greatly appreciated. Answer 1: There are several recent very good rulings on this subject. In N350711 (2025) CBP explained: It is the opinion of this office […]
Question: I cannot make heads or tails of the new guidance towards the 232 steel/aluminum/copper duties under the new Japan-US agreement. If there is an entry that has provided a breakdown of percentage for the acquisition cost of the steel, would the remaining commercial value still be subject to the reciprocal duties? Or has the […]
Question: The expanded Section 232 Steel and Aluminum Derivative Requirements include fragrances and cosmetics in chapter 33 and 34. Does this apply to the product only, or do we also need to provide a % breakdown for the packaging as well? Manufacturers seem to be having a difficult time providing the breakdown in general. Answer […]
Question: Good Day, I am seeking official documentation or guidance published directly by U.S. Customs and Border Protection (CBP) to verify information I received from a customs broker. Specifically, I was advised that when declaring the value on CBP Form 7501, I can separate the value of the raw steel material from the value added […]
Question: We are able to obtain the weight and value of the Al /Steel content as needed from the producer of our finished item but the question has arisen, since it’s the value of the Al/Steel content that is required can the apportioned value of the raw Al/Steel used to make a component within the […]
Question: We are having difficulty obtaining smelt and cast products from our suppliers, especially for aluminum and steel derivative parts. (Section 232) What are our options for shipping them anyway? We have spoken with other companies and brokers, and they have told us to indicate “unknown” and that everything would be subject to the highest […]
Question: Hi, we have several discussions how we as Supplier have to calculate the % of value and content of Al, Fe and Cu in our products exported to US. Is correct to use the % of price which is on invoice to US? Can we use % of our purchased cost only? As example: […]
Question: A couple of questions with regards to 232 on steel derivatives, please. 1). For purposes of calculating Section 232 tariffs on steel articles imported into the United States, is it permissible to exclude the value of scrap from the total cost of the coil? Assuming we are using coil to produce the steel good […]
Question: What type of proof is being requested from suppliers to prove origin of steel and aluminum derivative products? Is the Mill Test Certificate or Certificate of Analysis being requested? Is this easily available? When looking at copper would the wire in the cords of any electric consumer goods be considered a derivative product? This […]
Question: What metallurgical compositions are included in the derivatives list, specifically regarding iron and mild steel? Additionally, how does the carbon content affect the qualification for Section 232 duties? This feels like it should be a small question but how many carbon atoms will qualify or disqualify this under Section 232 duties? Answer 1: As […]
