The below is an update to the 7/21/2025 Customer Advisory, CBP Strengthens Enforcement on Section 232 Valuation:

The Corporate Compliance Team at RIM reached out to the CBP Centers of Excellence and Expertise (CEE) Base Metals Group, to obtain clarification on how to properly assess the aluminum and steel content for goods that fall under Section 232.  Please see below for the guidance that was provided.

Question: For a derivative aluminum article classified in chapter 76 or a derivative steel article classified in chapter 73 that is 100% aluminum or steel, can the importer report the raw material aluminum or steel cost for 232 assessment and report the conversion costs (labor, utilities, overhead) and profit on a separate line as “non-aluminum” or “non-steel” content to which the reciprocal tariff applies?

Response:

• From our conversations with HQ and what has been posted on cbp.gov, this is what we understand:
• Steel articles of chapter 72 are 100% steel. Section 232 duty is assessed on the full entered value of the article.
• For steel articles of chapter 73 and aluminum articles of chapter 76,
  • if the articles are 100% steel or 100% aluminum, there is NO non-steel/aluminum content to separate and Section 232 duty is assessed on the full entered value of the article. [This position has remained constant.]
  • if the articles are not wholly of steel or aluminum, the Section 232 duty is assessed on the steel/aluminum content of the article.
    • HQ has said this would be based on “the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content.” The most recent position is this is what the importer paid for the steel/aluminum content of the finished article, and is the entered value of the imported article minus the cost of the non-steel portion of the article.

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

If allowed to separate out steel/aluminum and non-steel/aluminum content value, many importers have asked what costs they can exclude. There is no HQ guidance provided for “backing out” costs to arrive at the steel/aluminum content value for articles that that are not wholly of steel or aluminum.  

As stated before, for articles that are wholly made of steel or aluminum, there is no backing out of any costs not allowed by the Customs Value laws.

For documentation separating steel/aluminum content value from non-steel/aluminum value, we would recommend providing “documentation sufficient to support the importer’s claimed steel/aluminum content value,” if requested by CBP.

To stay on top of additional guidance, watch the CSMS messages and Trade Remedy FAQs:

Cargo Systems Messaging Service | U.S. Customs and Border Protection
Trade Remedies | U.S. Customs and Border Protection

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.