The below is an additional update regarding Section 232 valuation, following our previous advisories:

• July 21st, 2025: CBP Strengthens Enforcement on Section 232 Valuation
• September 23rd, 2025: Update – CBP Strengthens Enforcement on Section 232 Valuation

CBP’s Base Metals Team at the Center of Excellence and Expertise has recently released new guidance on calculating steel, aluminum, and copper content for Section 232 duty calculation purposes.

If an article legitimately contains non-steel, non-aluminum, or non-copper content that can be separated, CBP’s position is as follows:

Steel articles of Chapter 72
Steel articles classified under Chapter 72 are considered 100% steel. Section 232 duty is assessed on the full entered value of the article. There is no backing out of any costs not allowed under Customs Valuation laws. Manufacturing, labor, coating, and similar costs are not subtracted.

Steel articles of Chapter 73, aluminum articles of Chapter 76, and articles classified elsewhere (excluding Chapter 72):

• If the articles are 100% steel or 100% aluminum, there is no non-steel or non-aluminum content to separate, and Section 232 duty is assessed on the full entered value of the article. There is no backing out of any costs not allowed under Customs Valuation laws. Manufacturing, labor, coating, and similar costs are not subtracted.
• If the articles are not wholly of steel or aluminum (i.e., they contain non-steel or non-aluminum parts or components), Section 232 duty is assessed on the steel or aluminum content of the article.

CBP Headquarters has stated this should 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 current position is that this represents what the importer paid for the steel or aluminum content of the finished article. This amount is calculated as the entered value of the imported article minus the cost of the non-steel or non-aluminum part or component of the finished article. Non-steel or non-aluminum content does not include fabrication, machining, labor, or similar costs.

When permitted to separate steel or aluminum content from non-steel or non-aluminum content, only the cost to the importer of the non-steel or non-aluminum part or component may be separated. There is no backing out of any costs not allowed under Customs Valuation laws. Manufacturing, labor, coating, and similar costs are not subtracted.

If the value of the steel or aluminum content cannot be determined, the duty must be reported based on the total entered value on a single entry summary line.

Surface treatments such as galvanizing and anodizing are considered integral to the finished steel product and are not separate components or parts. Paint, lacquer, and other coatings are also not considered parts, and their costs cannot be deducted.

Example cited:

Importers may need to ask manufacturers or sellers additional questions compared to past practice. For example, consider a window:

• What did the importer of record pay for the finished window?
• If the window contains non-steel components or parts, such as glass, what was the cost of those components to the importer?

The cost to the importer of the non-steel parts is subtracted from the total cost of the window to determine the Section 232 steel content value.

For example:

• The importer paid $100 for the window.
• $20 of that cost is attributable to glass or other non-steel components.

The entered value of the window is $100. It may be separated into two lines: a non-steel content line of $20 and a steel content line of $80.

CBP has not posted any new guidance recently; however, we encourage you to continue monitoring CSMS messages, Trade Remedy FAQs, and CBP rulings posted on cbp.gov.

Cargo Systems Messaging Service | U.S. Customs and Border
Trade Remedies | U.S. Customs and Border Protection
CROSS Custom Rulings Online Search System

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.