Dear Customers, Colleagues, and Friends,
We are sharing a brief update regarding how U.S. Customs and Border Protection (CBP) is currently evaluating the value of steel, aluminum, and non-metal content for purposes of Section 232 duties and certain IEEPA-based tariffs. While no formal, binding CBP ruling has been issued, recent CBP enforcement activity makes this an important compliance topic for importers.
Current CBP Position
CBP has stated that the value of steel or aluminum content should be determined using standard customs valuation principles under 19 U.S.C. § 1401a, generally based on the price paid or payable for that metal content, excluding international freight and insurance.
However, CBP has not issued binding Headquarters guidance, and enforcement interpretations continue to evolve.
CBP scrutiny has increased in two common situations:
- Products that are 100% steel or aluminum, especially where additional processing (coating, galvanizing, fabrication, etc.) occurs before sale to the U.S. importer.
- Products containing both metal and non-metal components, where steel or aluminum represents a substantial portion of the product.
Recent Informal CBP Interpretation
Through Notices of Action and entry reviews, CBP’s Base Metals Center has applied the following approach:
1) 100% steel or aluminum products
CBP has taken the position that fabrication, labor, coating, and processing costs are not excluded, potentially resulting in Section 232 duties assessed on the entire entered value.
2) Mixed-material products
CBP has interpreted metal content value as the entered value minus only the value of non-metal parts/components. Fabrication, machining, and labor are not treated as non-metal content.
What This Means for You
- Valuation methodology may be questioned during CBP review.
- Importers should document and internally approve their valuation approach.
- Conservative reporting may reduce enforcement risk until CBP issues formal guidance.
- Importers may seek binding rulings, internal advice, or protests if they disagree with CBP’s position.
We will continue to track all detailed guidance and will notify you as further regulatory instructions are released. In the meantime, if you have any questions or would like to discuss potential impacts on your shipments or sourcing strategy, our team at Krenz & Hannan is ready to assist.
Sincerely, Your friends at Krenz and Hannan International