On April 27, 2026, the Department of Commerce published a Federal Register notice adding a new duty-free code in the Harmonized Tariff Schedule of the United States (HTSUS). The addition resolves a discrepancy for goods classified under HTSUS Chapters for steel, aluminum, and copper that were subject to 232 tariff classification even though they did not contain any of these elements. The provision, subheading 9903.82, applies retroactively to April 6, 2026.
Recent 232 Developments
This notice is the latest in a series of adjustments to 232 tariffs on steel, copper, iron, and aluminum.
On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. Key elements of the proclamation include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, and manufacturing drawback claims. Read more here.
CBP has attempted to help importers navigate 232 tariffs. The agency recently published FAQs and CSMS messages on steel and aluminum about how to calculate and report the value of the steel and aluminum content of steel and aluminum derivative articles.
232 has been a hot topic at the Court of International Trade (CIT) as well. There is a current case challenging how CBP has been valuing and applying Section 232 tariffs on steel and aluminum derivative products. Express Fasteners, Ltd. ofIllinois filed the lawsuit, arguing that its imports of screws and fasteners were unlawfully assessed Section 232 steel duties.
What Importers Should Do
All importers should revisit their classification processes to ensure that their products are classified correctly, and that the proper duties are applied. Importers should also prioritize proper documentation and recordkeeping, as CBP may ask for detailed breakdowns and supporting analysis at any time. CBP enforcement is on the rise, and penalties for tariff evasion, even if incidental, can be significant.
Diaz Trade Law will continue to monitor developments and will provide additional information as it becomes available. In the meantime, contact us for assistance with valuation procedures, recordkeeping, staff training, and more. 305-456-3830, info@diaztradelaw.com
Learn more:
- ICYMI: Trump Administration Imposes 25% Steel and Aluminum Tariff
- Section 232 Valuation in a Gray Area: What Importers Need to Know
- New Executive Order Adjusting Imports of Aluminum, Steel, and Copper into the United States
- Bloomberg Law: CBP Recordkeeping Requirements
- Bloomberg Law: Import Compliance & Training Programs
- Bloomberg Law: Bloomberg Law Feature: Responding to CBP Form 28 or 29
- Webinar: Navigating CBP Regulations: Essential Practices for Import Success
- Webinar: Building and Maintaining an Effective Import Compliance Plan
- Webinar: Introduction to Importing
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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