The following was taken in part from CSMS #65794272:

On July 30th, President Trump issued a Fact Sheet and Presidential Proclamation imposing tariffs of 50% on imports of semi-finished copper and intensive copper derivative products pursuant to Section 232 of the Trade Expansion Act of 1962 due to a threat to national security.

These tariffs will be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 AM EDT on August 1st. 

Heading 9903.78.01:
50 percent additional ad valorem rate of duty on the copper content of semi-finished copper and intensive copper derivative products.

Heading 9903.78.02:
0 percent additional ad valorem rate of duty on:

• the non-copper content of semi-finished copper and intensive copper derivative products; and
• imported goods under the subject HTSUS classifications which contain no copper.

Reporting Instructions for Applying Duties Based on Copper Content (HTSUS 9903.78.01)

The 50 percent duty is to be reported based upon the value of the copper content.

The value of the copper content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a.

The value of the copper 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, or for the benefit of, the seller of the copper content.
• Normally, this would be based on the invoice paid by the buyer of the copper content to, or for the benefit of the seller of the copper content.

For imported articles composed only of copper, the dutiable value of the copper content is the total entered value, and the duty must be reported under the HTSUS 9903.78.01 classification based on the total entered value on only one entry summary line. 

If the value of the copper content cannot be determined, then report the duty based on the total entered value on only one entry summary line.

For all Section 232 duties based on copper content which are based on a value other than the entire value of the good, importers must keep documentation to support the reported values and provide to CBP upon request. Examples of such documentation include, but are not limited to, the bill of materials for the production of the goods, invoices for the materials used in the production of the goods, and accounting documentation to substantiate the reported values.

When insufficient documentation is provided to substantiate the reported values, CBP will collect the duties on the copper content based on the entire value of the good.

Importers who submit underreported declarations may be subject to severe consequences, such as significant monetary penalties, loss of import privileges, and criminal liability consistent with United States law.

Duties Applying to the Non-Copper Content

Per the July 30th, 2025 Proclamation, the non-copper content of all subject copper articles shall be subject to any other import duties in effect, including import duties established by Presidential Proclamations, except as specified below. 

Exemption for Goods Subject to Section 232 Duties on Auto Parts

If an imported good is subject to both the Section 232 duties on automobiles and automobile parts under Proclamation 10908, as amended, and the Section 232 duties on copper and copper derivative products, then the Section 232 duties on copper and copper derivative products are not applicable.

IEEPA Reciprocal Tariff Exception

International Emergency Economic Powers Act (IEEPA) Reciprocal tariff exception 9903.01.33 applies to goods subject to Section 232 tariffs including semi-finished copper and intensive copper derivative products provided for in 9903.78.01.

DRAWBACK

No drawback shall be available with respect to the duties imposed pursuant to the July 30th, 2025 Proclamation.

FOREIGN TRADE ZONE

Any product, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by the July 30, 2025 Proclamation and that is admitted into a US foreign trade zone on or after the effective date of August 1st, 2025, must be admitted as “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTSUS subheading.

The list of Copper HTSUS can be found here.

RIM logistics, ltd. will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative if you have any further questions.