CAPE Phase 2 Filing Requirements
CAPE Phase 2 Expansion Entries Flagged for Reconciliation
Effective today, June 29, 2026, U.S. Customs and Border Protection (CBP) has officially launched CAPE Phase 2. This update expands the CAPE tool to accept entries flagged for reconciliation (opening up potential IEEPA duty refunds) but requires strict adherence to a specific filing sequence.
Please note that all entry types previously eligible under CAPE Phase 1 remain fully eligible and can still be processed normally under this updated system.
The Core Rule of CAPE Phase 2
The new capabilities apply ONLY to entries where the Reconciliation entry has not yet been filed.
- Eligible Entries: Entry Types 01 (Formal), 02 (Quota), and 06 (FTZ) that are flagged for reconciliation.
- The Condition: The entries must be unliquidated or within 80 days of their liquidation date, and the final Reconciliation Summary (Entry Type 09) must not be on file yet.
- Future Phases: If you have already filed the Type 09 reconciliation for an entry, it is excluded from this phase and must wait for a future CAPE rollout.
Approaching Deadlines and The Correct Sequence
Because CAPE must remove the IEEPA duties before the reconciliation is finalized, timing is everything. If you have a reconciliation deadline fast approaching, CBP guidance dictates the following priority:
- Prioritize the Reconciliation: Do not let the deadline pass while waiting.
- Handling Increased Duties: If the reconciliation would result in increased IEEPA duties, file the reconciliation and deposit the standard duties, taxes, and fees owed, but exclude the increased IEEPA duties from your deposit.
How We Can Help
The sequencing here is highly precise. If you have eligible entries flagged for reconciliation and want to leverage the new CAPE Phase 2 capabilities to claim your refunds, please reach out to our office so we can coordinate the timing of your filings.
For full technical details, please see the official message from CBP below.
CSMS # 69066837 - DEPLOYED – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds - Entries Flagged for Reconciliation
U.S. Customs and Border Protection (CBP) has completed the successful deployment for enhancements to the Consolidated Administration and Processing of Entries (CAPE) application in the Automated Commercial Environment Secure Data Portal (ACE Portal). Importers and authorized customs brokers can now include in their CAPE declarations, submitted in the ACE Portal, entries flagged for reconciliation (entry types 01, 02, 06) for which the reconciliation entry (entry type 09) has not been filed. Consistent with CAPE Phase 1, the entries flagged for reconciliation will be limited to unliquidated entries and entries that have been liquidated within 80 days of the CAPE declaration filing date.
As a reminder, all filing and processing requirements from the first phase of CAPE remain in effect. For detailed information, please see CSMS # 68340863 - UPDATE - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026, Deployment.
If you encounter any errors in filing a CAPE declaration, contact your CBP client representative or the ACE Help Desk.
Questions regarding this message should be directed to CBP at IEEPAREFUNDS@cbp.dhs.gov.
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CAPE Phase 2
Please see the following message from CBP regarding CAPE 2. Entries flagged for reconciliation will be able to use CAPE to request refund of IEEPA. Entries that have already been reconciled (meaning a reconciliation entry has been filed) will not be able to be included in CAPE 2.
CSMS # 69035485 - UPDATE – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds - Entries Flagged for Reconciliation
On April 20, 2026, U.S. Customs and Border Protection (CBP) launched the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment to process refunds of International Emergency Economic Powers Act (IEEPA) duties. The purpose of this message is to provide updated guidance on the availability as of June 29, 2026, of new functionality for CAPE that provides for the acceptance of entries flagged for reconciliation with no reconciliation entry on file.
GUIDANCE
Entries Flagged for Reconciliation with No Reconciliation on File
All filing and processing requirements from the first phase of CAPE remain in effect. For detailed information, please see CSMS # 68340863 - UPDATE - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026, Deployment. Effective June 29, 2026, CAPE will accept entries flagged for reconciliation (entry types 01, 02, 06) for which the reconciliation entry (entry type 09) has not been filed. Consistent with CAPE Phase 1, the entries flagged for reconciliation will be limited to unliquidated entries and entries within 80 days of liquidation.
Once the entries flagged for reconciliation are accepted on a CAPE declaration, the trade may file the reconciliation entry. The CAPE process removes the IEEPA duties from the flagged entries prior to the filing of the reconciliation entry, separating the IEEPA duty refund from the calculations on the reconciliation entry. Once the reconciliation entry is filed, CBP will assume that all the CAPE declarations associated with the reconciled entries were filed and accepted. Once a reconciliation entry is filed, the underlying entries will not be eligible to be filed on a CAPE Declaration in this phase, pursuant to the June 29, 2026, deployment.
Entries Flagged for Reconciliation with Reconciliation on File
Entries flagged for reconciliation with the reconciliation entry already on file are not included in the June 29, 2026CAPE deployment. The CAPE process does not prevent an entry from being reconciled. If the reconciliation filing deadline is close to expiring (e.g., less than 30 days), the trade will need to prioritize the filing of the reconciliation. Entries flagged for reconciliation with a reconciliation entry already on file will be included in a future phase of CAPE development.
As future CAPE enhancements are deployed, CBP will issue Cargo Systems Messaging Service (CSMS) messages providing filing requirements and guidance.
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
Questions regarding this message should be directed to CBP at IEEPAREFUNDS@cbp.dhs.gov.
If you have any questions, please contact our office.
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CPSC eFiling Requirement Begins July 8, 2026
CPSC Certification Update
Beginning July 8, 2026, IAB will be required to submit your CPSC certification with entry information.
It is of the utmost importance that you are informed of the CPSC eFiling requirements and whether your product is subject to these regulations. We do not have the necessary knowledge about your products and manufacturers to assist you with this task.
The CPSC has provided the following resourceful guidance on setting up your product registry.
Watch the webinar video that provides a general overview of the eFiling process.
Please contact our office at compliance@iab-sd.com if you have questions.
Free CBP Webinar - ACE Portal Account Set Up
Please see the following message from NCBFAA regarding a free CBP webinar on how to set up and manage an ACE Portal Account.
CBP Webinar – with New Registration Link: How to Set Up and Manage an ACE Portal Account on June 17
NCBFAA Regular Member Customs Brokers and their Importer Clients are encouraged to register for the Customs and Border Protection (CBP) Office of Trade webinar, How to Set Up and Manage an ACE Portal Account, on Wednesday, June 17, at 11 a.m. ET.
“This webinar will provide an overview on how to set up an ACE Portal Account, along with information on new Webforms, and Trade Account Owner (TAO) functionality. We will also address common questions and solutions and provide an overview of recent portal improvements,” CBP said.
To register for this free webinar, click here. All registrants will receive the access link for the webinar the day before the event, but entry into the webinar is on a first-come, first-served basis as seats are limited, CBP said. After the live event, this and other previously recorded webinars will be available for replay at Trade Outreach Webinars | U.S. Customs and Border Protection (cbp.gov).
If you have any questions about this webinar, contact CBP at OTRwebinars@cbp.dhs.gov.
If you have any questions, please contact our office.
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CBP Guidance for Imports of Aluminum, Steel and Copper
U.S. Customs and Border Protection has released the following notice regarding the changes to aluminum, steel and copper imports.
CSMS # 68855869 - GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States
The purpose of this message is to provide guidance on the implementation of the June 1, 2026, Proclamation, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States.”
BACKGROUND
On April 2, 2026, the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). This proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective April 6, 2026. See 91 FR 18201 and CSMS 68253075.
On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending Proclamation 11021, adding new metals derivatives subject to Section 232 duties and reducing the Section 232 duty rates for other derivatives. See 91 FR 34085.
GUIDANCE
This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) on certain steel, aluminum, and copper articles and their derivatives from all countries as provided in Harmonized Tariff Schedule of the United States (HTSUS) headings 9903.82.01 to 9903.82.26. Separate instructions will be provided on HTSUS headings 9903.82.18 and 9903.82.19 at a later date.
Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026:
The following HTSUS classifications will be subject to Section 232 duties under Proclamation 11021, as amended:
3701.30.00
9403.20.0075
9403.20.0082
9403.99.9040
The following HTSUS classifications will be subject to reduced Section 232 duty rates:
| 8407.90.10 | 8429.59.10 | 8701.93.10 |
| 8415.10.60 | 8429.59.50 | 8701.93.50 |
| 8415.10.90 | 8431.20.00 | 8701.94.10 |
| 8415.81.01 | 8431.42.00 | 8701.94.50 |
| 8415.82.01 | 8431.49.90 | 8701.95.10 |
| 8415.90.80 | 8432.10.00 | 8701.95.50 |
| 8419.81.50 | 8432.90.00 | 8703.21.01 |
| 8427.10.40 | 8433.20.00 | 8705.10.00 |
| 8427.10.80 | 8433.51.00 | 8705.20.00 |
| 8427.20.40 | 8433.59.00 | 8706.00.30 |
| 8427.20.80 | 8433.90.50 | 8708.29.2120 |
| 8427.90.00 | 8479.89.55 | 8708.29.2130 |
| 8429.11.00 | 8479.89.65 | 8708.40.30 |
| 8429.19.00 | 8516.29.00 | 8708.40.60 |
| 8429.20.00 | 8701.10.01 | 8708.92.10 |
| 8429.30.00 | 8701.30.10 | 8708.92.60 |
| 8429.40.00 | 8701.30.50 | 8708.93.15 |
| 8429.51.10 | 8701.91.10 | 8708.93.30 |
| 8429.51.50 | 8701.91.50 | 8708.99.23 |
| 8429.52.10 | 8701.92.10 | 8716.80.10 |
| 8429.52.50 | 8701.92.50 | 8716.90.10 |
See the attachment for the Chapter 1 to 97 HTSUS classifications which correspond to each Chapter 99 heading. All changes listed above are indicated in bold in the attachment.
Except for the changes listed above, for HTSUS 9903.82.01 to 9903.82.19, the additional duties were effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on April 6, 2026.
Headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 were effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on April 6, 2026, and before January 1, 2028.
For HTSUS 9903.82.20 to 9903.82.26, the additional duties will take effect with respect to goods entered for consumption, or withdrawn from warehouse for
consumption, on or after 12:01 a.m. eastern time on June 8, 2026, and before January 1, 2028.
Effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on January 1, 2028:
- the goods covered by headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, and 9903.82.09; and.
- the goods covered by HTSUS 9903.82.20 to 9903.82.26 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, 9903.82.09, 9903.82.15 and 9903.82.16.
Additional guidance will be provided prior to January 1, 2028.
9903.82.01: Articles provided for in subdivision (c) of U.S. note 16 to this subchapter that do not contain any aluminum, steel, or copper.
0% additional ad valorem rate of duty
9903.82.02: Except as provided for in headings 9903.82.14, 9903.85.67 and 9903.85.68, applies to articles of aluminum, of steel, or of copper and derivative aluminum or steel articles, as provided for in subdivision (c)(i) -(v) of U.S. note 16 to this subchapter.
50% additional ad valorem rate of duty
9903.82.03: Except for articles classifiable in Chapters 72, 73, 74, or 76, articles where the weight of the applicable metal is less than 15 percent of the weight of the imported article, as provided for in subdivision (c) of U.S. note 16 to this subchapter.
0% additional ad valorem rate of duty
When reporting HTSUS 9903.82.03, report the aggregate weight of the applicable metal(s) in kg as a second quantity on the entry summary line.
9903.82.04: Applies to articles of aluminum or of steel and derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(i)-(iv) and (d) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.05: Applies to derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(vi)-(vii) and (d) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026, the threshold for imported products to qualify as made "entirely" from American aluminum, steel, or copper, is modified from 95 percent to 85 percent, as follows:
Headings 9903.82.06, 9903.82.07, 9903.82.08, 9903.82.23 and 9903.82.24 apply to certain articles of copper and derivative aluminum and steel articles provided for in subdivision (c) of this note.
- For derivative articles provided for in subdivisions (c)(ii), (vi), and (ix), at least 85 percent of the aluminum content of the article must be composed of aluminum that was smelted and cast in the United States.
- For derivative articles provided for in subdivisions (c)(iv), (vii), (x) and (xi), at least 85 percent of the steel content of the article must be composed of steel that was melted and poured in the United States.
- For articles provided for in subdivision (c)(viii), at least 85 percent of the copper content of the article must be composed of copper that was smelt and cast in the United States).
- These requirements are cumulative such that a derivative article in more than one subdivision must satisfy each requirement.
9903.82.06: Except as provided for in headings 9903.82.15 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(ii), (iv), (vi) - (viii), (xi) and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.07: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 10%.
9903.82.08: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is 10 percent or higher, no additional duty is due.
9903.82.09: Except as provided for in headings 9903.82.16, 9903.82.20–9903.82.26 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(vi)-(viii) and (xi) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.10: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter
For articles for which the applicable column 1 duty rate is less than 15 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 15%.
9903.82.11: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter
For articles for which the applicable column 1 duty rate is 15 percent or higher, no additional duty is due.
9903.82.12: Except as provided for in headings 9903.82.17 and 9903.85.68 applies to derivative aluminum and steel articles, the product of any country identified in general note 3(b) (countries subject to the column 2 duty rates in the HTSUS), as provided for in subdivision (c)(ix)-(x) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.13: Applies to articles that otherwise meet the criteria of subdivisions (c)(vi)-(viii) and (xi) that are motorcycle parts classifiable in Chapter 84, 85, or 87 for use in the manufacturing of motorcycles in the United States.
0% additional ad valorem rate of duty
9903.82.14: Applies to articles of steel or of copper and derivative steel that are the product of the Russian Federation as provided for in subdivisions (c)(iii)–(v) of U.S. note 16 to this subchapter.
50% additional ad valorem rate of duty
9903.82.15: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(iv), (vii), (viii), (xi) and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.16: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(vii)–(viii) and (xi) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.17: Applies to derivative steel articles that are the product of the Russian Federation, as provided for in subdivision (c)(x) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
For headings 9903.82.18 and 9903.18.19, entry filing instructions will be provided at another time.
Headings 9903.82.20 and 9903.82.21: Apply to derivative steel articles provided for in subdivision (c)(xi) that are the products of Canada and Mexico and eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA).
9903.82.20: Applies to the non-U.S. content of derivative steel articles and to U.S. content that exceeds 40 percent of the value of such derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.21: Applies to the U.S. content of derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter, except that U.S. content that exceeds 40 percent of the value of such derivative steel articles shall be subject to the rates of duty provided in heading 9903.82.20.
0% additional ad valorem rate of duty
Do not report more than 40 percent of the value of the U.S. content of the good in heading 9903.82.21.
For the purposes of U.S. note 16, U.S. content refers to the value of the article attributable to parts produced in the United States. The non-U.S. content of the article shall be calculated by subtracting the value of the U.S. content in the article from the total value of the article.
See additional reporting instructions for HTSUS 9903.82.20 and 9903.82.21 below.
9903.82.22: Applies to derivative steel articles the product of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union, as provided for in subdivision (c)(xi) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
Headings 9903.82.23–9903.82.26 apply to parts classifiable in the provisions of subdivision (c)(vi)–(viii) that are in chapters 84, 85, or 87 that will be used exclusively in the manufacturing of agricultural equipment or fixed industrial equipment provided for in subdivision (c)(ix)−(x) or mobile industrial equipment provided for in subdivision (c)(xi). Headings 9903.82.23–9903.82.26 do not apply to products of any country identified in general note 3(b) (Belarus, Cuba, North Korea, and Russia).
9903.82.23: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column one duty rate and the additional ad valorem rate of duty will be 10%.
9903.82.24: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.
For articles for which the applicable column one duty rate is 10 percent or higher, no additional duty is due.
9903.82.25: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
9903.82.26: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.
0% additional ad valorem rate of duty
Reporting Instructions for Applying the Tariff Treatment Under HTSUS 9903.82.20 and 9903.82.21
When claiming treatment under HTSUS 9903.82.20 and 9903.82.21, the non-U.S. content and the U.S. content value of the derivative products must be reported on two lines.
The first line will represent the value of the non-U.S. content and the U.S. content that exceeds 40 percent of the value of such derivative steel articles, while the second line will represent the value of the U.S. content. Each line should be reported in accordance with the instructions below.
Non-U.S. content, first line:
Report the total quantity of the imported goods
Report the value of the non-U.S. content by subtracting the value of the U.S. content reported under HTSUS 9903.82.21 from the entered value of such derivative articles.
Report the Section 232 duties based on the value such content with HTSUS 9903.82.20.
Report Special Program Indicator (SPI) code “S”
Report Ch. 1-97 HTSUS, same HTSUS must be reported on both lines.
Report country of origin (Canada or Mexico), same country of origin must be reported on both lines.
Report all other applicable duties, such as antidumping and countervailing duties
U.S. content, second line:
Report 0 for quantity.
Report the entered value of the U.S. content, up to 40 percent of the total entered value of the imported goods
Report the 0 duties based on the value of U.S. content with HTSUS 9903.82.21.
Report Special Program Indicator (SPI) code “S”
Report the same Ch. 1-97 HTSUS reported on the first line.
Report the same country of origin reported on the first line.
Report all other applicable duties, such as antidumping and countervailing duties.
Russia Aluminum Duties
All imports of aluminum articles and aluminum derivative articles covered by this Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of these aluminum articles is smelt in Russia, or these aluminum articles are cast in Russia, shall continue to be subject to the 200 percent ad valorem rate of duty under HTSUS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products.
Russia aluminum and aluminum derivative products subject to HTSUS headings 9903.85.67 and 9903.85.68 may not be reported under HTSUS 9903.82.03.
Reporting of Countries of Melt and Pour and Smelt and Cast
Continue to report the countries of melt and pour for all subject steel and steel derivative products and the countries of smelt and cast for all subject aluminum and aluminum derivative products. See, e.g., Cargo System Messaging Service (CSMS) messages 64348411, 64348288, and 65340246 for reporting instructions.
CBP will issue a CSMS to announce when the reporting of the countries of copper smelt and cast will be required and the corresponding functionality is available in ACE for imports of copper products under the following HTSUS classifications:8544.42.10; 8544.42.20; 8544.42.90; and 8544.49.10.
Please note that imports under HTSUS 9903.82.03, 9903.82.13 and 9903.82.21 are not eligible for the Section 122 exemption for Section 232 products under HTSUS 9903.03.06. See CSMS # 67844987 - Imposing Temporary Section 122 Duties.
For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
If you have any questions, please contact our office.
Stay Updated on Customs Compliance
CBP Guidance for Imports of Aluminum, Steel and Copper
U.S. Customs and Border Protection has released the following notice regarding the changes to aluminum, steel and copper imports.
If you have any questions, please contact our office.
CSMS # 68855869 - GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States
The purpose of this message is to provide guidance on the implementation of the June 1, 2026, Proclamation, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States.”
BACKGROUND
On April 2, 2026, the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). This proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective April 6, 2026. See 91 FR 18201 and CSMS 68253075.
On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending Proclamation 11021, adding new metals derivatives subject to Section 232 duties and reducing the Section 232 duty rates for other derivatives. See 91 FR 34085.
GUIDANCE
This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) on certain steel, aluminum, and copper articles and their derivatives from all countries as provided in Harmonized Tariff Schedule of the United States (HTSUS) headings 9903.82.01 to 9903.82.26. Separate instructions will be provided on HTSUS headings 9903.82.18 and 9903.82.19 at a later date.
Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026:
The following HTSUS classifications will be subject to Section 232 duties under Proclamation 11021, as amended:
3701.30.00
9403.20.0075
9403.20.0082
9403.99.9040
The following HTSUS classifications will be subject to reduced Section 232 duty rates:
| 8407.90.10 | 8429.59.10 | 8701.93.10 |
| 8415.10.60 | 8429.59.50 | 8701.93.50 |
| 8415.10.90 | 8431.20.00 | 8701.94.10 |
| 8415.81.01 | 8431.42.00 | 8701.94.50 |
| 8415.82.01 | 8431.49.90 | 8701.95.10 |
| 8415.90.80 | 8432.10.00 | 8701.95.50 |
| 8419.81.50 | 8432.90.00 | 8703.21.01 |
| 8427.10.40 | 8433.20.00 | 8705.10.00 |
| 8427.10.80 | 8433.51.00 | 8705.20.00 |
| 8427.20.40 | 8433.59.00 | 8706.00.30 |
| 8427.20.80 | 8433.90.50 | 8708.29.2120 |
| 8427.90.00 | 8479.89.55 | 8708.29.2130 |
| 8429.11.00 | 8479.89.65 | 8708.40.30 |
| 8429.19.00 | 8516.29.00 | 8708.40.60 |
| 8429.20.00 | 8701.10.01 | 8708.92.10 |
| 8429.30.00 | 8701.30.10 | 8708.92.60 |
| 8429.40.00 | 8701.30.50 | 8708.93.15 |
| 8429.51.10 | 8701.91.10 | 8708.93.30 |
| 8429.51.50 | 8701.91.50 | 8708.99.23 |
| 8429.52.10 | 8701.92.10 | 8716.80.10 |
| 8429.52.50 | 8701.92.50 | 8716.90.10 |
See the attachment for the Chapter 1 to 97 HTSUS classifications which correspond to each Chapter 99 heading. All changes listed above are indicated in bold in the attachment.
Except for the changes listed above, for HTSUS 9903.82.01 to 9903.82.19, the additional duties were effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on April 6, 2026.
Headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 were effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on April 6, 2026, and before January 1, 2028.
For HTSUS 9903.82.20 to 9903.82.26, the additional duties will take effect with respect to goods entered for consumption, or withdrawn from warehouse for
consumption, on or after 12:01 a.m. eastern time on June 8, 2026, and before January 1, 2028.
Effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on January 1, 2028:
- the goods covered by headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, and 9903.82.09; and.
- the goods covered by HTSUS 9903.82.20 to 9903.82.26 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, 9903.82.09, 9903.82.15 and 9903.82.16.
Additional guidance will be provided prior to January 1, 2028.
9903.82.01: Articles provided for in subdivision (c) of U.S. note 16 to this subchapter that do not contain any aluminum, steel, or copper.
0% additional ad valorem rate of duty
9903.82.02: Except as provided for in headings 9903.82.14, 9903.85.67 and 9903.85.68, applies to articles of aluminum, of steel, or of copper and derivative aluminum or steel articles, as provided for in subdivision (c)(i) -(v) of U.S. note 16 to this subchapter.
50% additional ad valorem rate of duty
9903.82.03: Except for articles classifiable in Chapters 72, 73, 74, or 76, articles where the weight of the applicable metal is less than 15 percent of the weight of the imported article, as provided for in subdivision (c) of U.S. note 16 to this subchapter.
0% additional ad valorem rate of duty
When reporting HTSUS 9903.82.03, report the aggregate weight of the applicable metal(s) in kg as a second quantity on the entry summary line.
9903.82.04: Applies to articles of aluminum or of steel and derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(i)-(iv) and (d) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.05: Applies to derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(vi)-(vii) and (d) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026, the threshold for imported products to qualify as made "entirely" from American aluminum, steel, or copper, is modified from 95 percent to 85 percent, as follows:
Headings 9903.82.06, 9903.82.07, 9903.82.08, 9903.82.23 and 9903.82.24 apply to certain articles of copper and derivative aluminum and steel articles provided for in subdivision (c) of this note.
- For derivative articles provided for in subdivisions (c)(ii), (vi), and (ix), at least 85 percent of the aluminum content of the article must be composed of aluminum that was smelted and cast in the United States.
- For derivative articles provided for in subdivisions (c)(iv), (vii), (x) and (xi), at least 85 percent of the steel content of the article must be composed of steel that was melted and poured in the United States.
- For articles provided for in subdivision (c)(viii), at least 85 percent of the copper content of the article must be composed of copper that was smelt and cast in the United States).
- These requirements are cumulative such that a derivative article in more than one subdivision must satisfy each requirement.
9903.82.06: Except as provided for in headings 9903.82.15 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(ii), (iv), (vi) - (viii), (xi) and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.07: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 10%.
9903.82.08: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is 10 percent or higher, no additional duty is due.
9903.82.09: Except as provided for in headings 9903.82.16, 9903.82.20–9903.82.26 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(vi)-(viii) and (xi) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.10: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter
For articles for which the applicable column 1 duty rate is less than 15 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 15%.
9903.82.11: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter
For articles for which the applicable column 1 duty rate is 15 percent or higher, no additional duty is due.
9903.82.12: Except as provided for in headings 9903.82.17 and 9903.85.68 applies to derivative aluminum and steel articles, the product of any country identified in general note 3(b) (countries subject to the column 2 duty rates in the HTSUS), as provided for in subdivision (c)(ix)-(x) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.13: Applies to articles that otherwise meet the criteria of subdivisions (c)(vi)-(viii) and (xi) that are motorcycle parts classifiable in Chapter 84, 85, or 87 for use in the manufacturing of motorcycles in the United States.
0% additional ad valorem rate of duty
9903.82.14: Applies to articles of steel or of copper and derivative steel that are the product of the Russian Federation as provided for in subdivisions (c)(iii)–(v) of U.S. note 16 to this subchapter.
50% additional ad valorem rate of duty
9903.82.15: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(iv), (vii), (viii), (xi) and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.16: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(vii)–(viii) and (xi) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.17: Applies to derivative steel articles that are the product of the Russian Federation, as provided for in subdivision (c)(x) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
For headings 9903.82.18 and 9903.18.19, entry filing instructions will be provided at another time.
Headings 9903.82.20 and 9903.82.21: Apply to derivative steel articles provided for in subdivision (c)(xi) that are the products of Canada and Mexico and eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA).
9903.82.20: Applies to the non-U.S. content of derivative steel articles and to U.S. content that exceeds 40 percent of the value of such derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.21: Applies to the U.S. content of derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter, except that U.S. content that exceeds 40 percent of the value of such derivative steel articles shall be subject to the rates of duty provided in heading 9903.82.20.
0% additional ad valorem rate of duty
Do not report more than 40 percent of the value of the U.S. content of the good in heading 9903.82.21.
For the purposes of U.S. note 16, U.S. content refers to the value of the article attributable to parts produced in the United States. The non-U.S. content of the article shall be calculated by subtracting the value of the U.S. content in the article from the total value of the article.
See additional reporting instructions for HTSUS 9903.82.20 and 9903.82.21 below.
9903.82.22: Applies to derivative steel articles the product of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union, as provided for in subdivision (c)(xi) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
Headings 9903.82.23–9903.82.26 apply to parts classifiable in the provisions of subdivision (c)(vi)–(viii) that are in chapters 84, 85, or 87 that will be used exclusively in the manufacturing of agricultural equipment or fixed industrial equipment provided for in subdivision (c)(ix)−(x) or mobile industrial equipment provided for in subdivision (c)(xi). Headings 9903.82.23–9903.82.26 do not apply to products of any country identified in general note 3(b) (Belarus, Cuba, North Korea, and Russia).
9903.82.23: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.
For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column one duty rate and the additional ad valorem rate of duty will be 10%.
9903.82.24: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.
For articles for which the applicable column one duty rate is 10 percent or higher, no additional duty is due.
9903.82.25: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.
15% additional ad valorem rate of duty
9903.82.26: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.
0% additional ad valorem rate of duty
Reporting Instructions for Applying the Tariff Treatment Under HTSUS 9903.82.20 and 9903.82.21
When claiming treatment under HTSUS 9903.82.20 and 9903.82.21, the non-U.S. content and the U.S. content value of the derivative products must be reported on two lines.
The first line will represent the value of the non-U.S. content and the U.S. content that exceeds 40 percent of the value of such derivative steel articles, while the second line will represent the value of the U.S. content. Each line should be reported in accordance with the instructions below.
Non-U.S. content, first line:
Report the total quantity of the imported goods
Report the value of the non-U.S. content by subtracting the value of the U.S. content reported under HTSUS 9903.82.21 from the entered value of such derivative articles.
Report the Section 232 duties based on the value such content with HTSUS 9903.82.20.
Report Special Program Indicator (SPI) code “S”
Report Ch. 1-97 HTSUS, same HTSUS must be reported on both lines.
Report country of origin (Canada or Mexico), same country of origin must be reported on both lines.
Report all other applicable duties, such as antidumping and countervailing duties
U.S. content, second line:
Report 0 for quantity.
Report the entered value of the U.S. content, up to 40 percent of the total entered value of the imported goods
Report the 0 duties based on the value of U.S. content with HTSUS 9903.82.21.
Report Special Program Indicator (SPI) code “S”
Report the same Ch. 1-97 HTSUS reported on the first line.
Report the same country of origin reported on the first line.
Report all other applicable duties, such as antidumping and countervailing duties.
Russia Aluminum Duties
All imports of aluminum articles and aluminum derivative articles covered by this Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of these aluminum articles is smelt in Russia, or these aluminum articles are cast in Russia, shall continue to be subject to the 200 percent ad valorem rate of duty under HTSUS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products.
Russia aluminum and aluminum derivative products subject to HTSUS headings 9903.85.67 and 9903.85.68 may not be reported under HTSUS 9903.82.03.
Reporting of Countries of Melt and Pour and Smelt and Cast
Continue to report the countries of melt and pour for all subject steel and steel derivative products and the countries of smelt and cast for all subject aluminum and aluminum derivative products. See, e.g., Cargo System Messaging Service (CSMS) messages 64348411, 64348288, and 65340246 for reporting instructions.
CBP will issue a CSMS to announce when the reporting of the countries of copper smelt and cast will be required and the corresponding functionality is available in ACE for imports of copper products under the following HTSUS classifications:8544.42.10; 8544.42.20; 8544.42.90; and 8544.49.10.
Please note that imports under HTSUS 9903.82.03, 9903.82.13 and 9903.82.21 are not eligible for the Section 122 exemption for Section 232 products under HTSUS 9903.03.06. See CSMS # 67844987 - Imposing Temporary Section 122 Duties.
For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
Stay Updated on Customs Compliance
Trump Administration Announces Major CBP Enforcement Reforms
President Trump has signed an Executive Order directing CBP to strengthen customs enforcement and close perceived gaps in importer compliance.
See the following message from NCBFAA for more details.
President Trump Signs Executive Order to Strengthen CBP Enforcement
President Trump on June 3 signed an Executive Order to straighten the enforcement capabilities of Customs and Border Protection (CBP), with a focus on the importer of record (IOR) and preventing the evasion of customs duties.
“Customs reform is long overdue. Systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes have created opportunities for malign actors to evade Federal law. Examples of noncompliance include undervaluing imports, withholding critical information about IORs and the goods being imported, and avoiding payment of duties through various arrangements and schemes. These actions threaten national security, undermine foreign relations, disadvantage domestic businesses, and harm Americans,” the Executive Order said.
“The United States must strengthen its customs enforcement through comprehensive reform, including through agency action and legislation. Such reform should focus on protecting national security, promoting lawful trade, ensuring the timely collection of duties, modernizing systems and processes, bolstering compliance mechanisms, increasing transparency, and protecting Americans and the domestic economy,” the order added.
The Executive Order states that within the 180 days of the date of this order, the Secretary of Homeland Security shall, pursuant to 19 U.S.C. 66, 1484, 1498, 1623, 1624, and 4320, and any other applicable law, take steps to revise importer eligibility regulations, guidance, and policies consistent with the policy of this order. These revisions shall include:
- Requiring that an IOR maintain at all times a minimum level of tangible domestic assets, bonding, or both, as determined by CBP to be necessary to ensure compliance with U.S. customs and trade laws, and increasing the minimum required bond coverage for an IOR.
- Requiring that an IOR be designated and reported to CBP, and that a bond, or sufficient tangible domestic assets, or both, be required, for all formal entries under 19 U.S.C. 1484 and informal entries under regulations promulgated pursuant to 19 U.S.C. 1498.
- Requiring that an IOR provide to CBP additional data and identification information, including anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures, and any other data that CBP deems necessary.
The Executive Order added that prohibiting the filing of informal entries for foreign IORs puts all IORs on “equal footing and is necessary to treat IORs equally based on their individualized circumstances and in order to protect U.S. revenue and domestic industry, protect American consumers, strengthen national security, and maintain foreign relations.”
The Executive Order further said a foreign IOR: (1) may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP when the foreign IOR has demonstrated that the revenue would be fully protected and that compliance with the laws, regulations, and instructions enforced by CBP would be assured; and (2) be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT), if determined by CBP to be eligible.
“IORs not in “good standing” with CBP shall not be allowed to import into the United States or otherwise conduct activities directly related to the importation of goods, including designating a customs broker to act as IOR on their behalf,” the order added.
President Trump’s order also stated that the DHS Secretary must establish heightened import disclosure and certification requirements, including certifying compliance with critical supply chain requirements like the Countering America’s Adversaries through Sanctions Act (Public Law 115-44), 18 U.S.C 545, and others to be determined by CBP, in consultation with the heads of relevant executive departments and agencies (agencies); disclosing certain foreign tax and global business identifiers; and providing detailed information about the imported good’s supply chain and production methods, such as the manufacturer’s product identifier (e.g., model or style number) or key specifications (e.g., composition, grade, or size).
CBP enforcement and penalties for wrongdoing will be enhanced by the administration through this Executive Order, including enforcing liquidated damages claims against bonds for noncompliance, restricting in-bond utilization, increasing audits, and imposing maximum penalties for customs brokers who fail to conduct due diligence, repeatedly represent noncompliant clients, or fail to cooperate in a timely manner with requests for information by CBP.
In addition, the Executive Order states that enforcement action will be heightened by CBP against imports involving products produced by forced labor, misclassification, undervaluation, and illegal transshipment, including investigations conducted pursuant to the Enforce and Protect Act (Public Law 114-125).
If you have any questions, please contact our office.
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