Updated 232 Guidance from CBP Base Metals Center

Updated 232 Guidance from CBP Base Metals Center

CBP has issued guidance that has been shared with the trade regarding Section 232 content value, following confusion within the industry about what costs may and may not be deducted from Customs value. This guidance was provided on December 3.

According to the guidance provided, the following costs are not permitted to be broken out or deducted from the declared value:

• Overhead and processing costs for steel, aluminum, or copper, as these are not considered non-steel, non-aluminum, or non-copper costs.
• Surface treatments for steel, such as galvanizing, anodizing, and the application of paint, lacquer, or other coatings. CBP considers these treatments integral to the finished steel product and therefore not deductible from the steel content value for Section 232 duty purposes.
• “Steel articles of Chapter 72 are 100% steel”, which CBP states in the attached guidance. Deductions for derivative articles classified elsewhere are not permitted.
• Manufacturing, labor, fabrication, and machining costs, which may not be broken out of the steel or aluminum value for Section 232 purposes.

CBP also clarified that packing costs included for both non-steel/aluminum/copper content and steel/aluminum/copper content must be apportioned across both.

Additionally, the Base Metal Center has indicated that the current understanding is that copper is treated the same as steel and aluminum for purposes of Section 232 tariffs, including as it relates to alloys.

CBP further clarified that copper articles and copper alloy articles, such as brass, are treated the same as steel and aluminum alloys and are therefore subject to Section 232 duties. CBP does not permit breaking down the chemistry of imported articles to determine a copper-only value, as chemistry is not considered a separate component or part. Accordingly, the value of alloying elements may not be deducted.

Additionally, CBP stated that if an importer elects to separate out the steel or aluminum content value, the importer must be able to provide documentation sufficient to support the claimed steel or aluminum content value upon request by CBP.

By way of example, CBP explained that for an imported window, the filer should begin with the price paid for the finished window and then subtract the cost to the importer of non-steel components, such as glass, in order to determine the applicable Section 232 steel content value.

Linked below is the full guidance that was provided by CBP Base Metal Center.

BMCEE Guidance on Section 232 Content Value_12.3.25

If you have any questions, please reach out to your Western Overseas representative.