9903.82.01: Section 232\u2019s new no-metal-no-tariff subheading. Do your entries qualify for the 0% rate?
CSMS #68554727 and 91 FR 23056. Retroactive to 6 April 2026. If your HTS code is in Note 16(c) but your product contains no aluminum, steel or copper, you are paying Section 232 duty you do not owe. The Post-Summary Correction window is open. The clock is ticking.
The rule in plain English
On 6 May 2026 CBP published CSMS #68554727 and the Federal Register notice at 91 FR 23056. Both add a new subheading to Chapter 99 of the HTSUS: 9903.82.01. The subheading carries a 0% additional ad valorem rate of duty. It applies to articles whose HTS classification falls within US Note 16(c) but which do not contain any aluminum, steel or copper. In other words, if the HTS code captures both metal and non-metal versions of a product, and your version is the non-metal one, you now have a dedicated Chapter 99 subheading to declare. Section 232 duty does not apply.
The provision is retroactive. Effective 12:01 a.m. Eastern Time on 6 April 2026. Entries already filed at a Section 232 rate after that date are eligible for correction back to that rate where the article contains no aluminum, steel or copper. The correction vehicle is the Post-Summary Correction (PSC) where the entry is pre-liquidation. Or the Protest where the entry has already been liquidated. The PSC window runs 314 days from entry summary acceptance. For the earliest qualifying entries, that window already started running in April.
Source documents
- CSMS #68554727 (CBP Cargo Systems Messaging Service, 6 May 2026)
- 91 FR 23056 (Federal Register notice)
- White House Section 232 Proclamation Annex IV
- US Note 16(c) of HTSUS Chapter 99 Subchapter III
Three criteria. All three must be met.
If any one fails, 9903.82.01 does not apply to that entry.
Your HTS code is in Note 16(c)
US Note 16(c) lists the HTS codes covered by the Section 232 metals action. Categories (i) through (x) include aluminum and steel base materials, derivative aluminum and steel articles, copper, and the Russia-specific subcategories. The full list is in HTSUS Chapter 99 Subchapter III. If your HTS code is not on the list, Section 232 does not apply and neither does 9903.82.01.
Your product contains zero aluminum, steel or copper
This is the critical test. The HTS code may capture both metal and non-metal versions of a product. The new 9903.82.01 subheading is for the non-metal version. If your product contains any aluminum, steel or copper at all, this subheading does not apply. You are in one of the other Chapter 99 headings (9903.82.02 through 9903.82.17) at the relevant rate (10%, 15%, 25%, 50% or 200%).
You can document the material composition
CBP requires evidence. The Bill of Materials from the manufacturer. The supplier\u2019s metal content declaration. Mill test reports where applicable. The product specification sheet. Where the documentation supports the zero-metal claim, the 9903.82.01 subheading is defensible at audit. Where it does not, the claim creates exposure.
All three criteria met means the entry qualifies for 9903.82.01 and any Section 232 duty paid is recoverable through your broker.
Retroactive to 6 April 2026. The PSC clock is running.
The 9903.82.01 subheading applies retroactively to entries filed for consumption (or withdrawn from warehouse for consumption) on or after 12:01 a.m. Eastern Time on 6 April 2026. Entries filed at a higher Section 232 rate after that date can be corrected through your licensed broker. Two filing vehicles are available, both with hard deadlines.
Post-Summary Correction (PSC)
Within 314 days of entry summary acceptance
Available pre-liquidation. Filed by the licensed customs broker through ACE. Preferred vehicle where the entry has not yet liquidated.
Protest (CBP Form 19)
Within 180 days of liquidation
Available post-liquidation. Filed by the licensed customs broker. Preserves the right to further review in the Court of International Trade.
The clock is running
Earliest qualifying entries were filed on 6 April 2026. The PSC window on those entries closes around 14 February 2027. Every week of delay shortens the window for that week\u2019s entries. Importers running high volume through Note 16(c) HTS codes should be assessing now, not in three months.
Single-source ACE audits cannot see the metal content
An ACE audit shows what was declared. The HTS code, the country of origin, the duty paid, the entered value. It does not show what the article actually is. Whether the derivative steel article at HTS 7308.20.0035 is a structural steel beam or a composite product with no steel content is not visible in the ACE data. The HTS is the same. The Section 232 rate at filing was the same. The 9903.82.01 candidate cannot be identified from ACE alone.
To surface 9903.82.01 candidates, you need to reconcile the HTS code against the importer\u2019s Bill of Materials and the supplier\u2019s material composition declarations. That is a six-source audit, not a single-source audit. ACE plus BOM plus commercial invoice plus supplier composition certificate plus broker entry worksheet plus (where applicable) the SIMA, AIM or CIMA license. We reconcile all six. Where the BOM and the composition certificate show zero aluminum, steel or copper for an entry filed under a Note 16(c) HTS, the entry is a 9903.82.01 candidate. We flag it. Your broker reviews it. Your broker files the PSC.
Single-source ACE audits return \u2018clean\u2019 on entries carrying refundable Section 232 duty. The data behind the data is where 9903.82.01 candidates live.
Four-stage workflow
Ingest
We ingest your ACE entry data from 6 April 2026 onwards. The platform identifies every entry filed under a Note 16(c) HTS code at a Section 232 rate (9903.82.02 through 9903.82.17). These are the candidates pool.
Reconcile
For each candidate, we reconcile the HTS code against your Bill of Materials, the supplier\u2019s material composition declaration, the commercial invoice and the broker entry worksheet. The Piers AI engine identifies discrepancies: HTS suggests metal content, BOM shows zero. These are the 9903.82.01 flags.
Document
For each flagged candidate, we package the supporting documents into a PSC submission file: the original 7501, the BOM showing zero metal content, the supplier composition certificate, the commercial invoice, the recalculated duty showing the refundable amount. Ready for your licensed broker to review.
Broker reviews and files
Your licensed customs broker reviews each candidate file, applies broker judgment on whether the qualification is defensible, and files the PSC with CBP. We never file. The broker holds the regulated activity and invoices you directly for the filing work.
Your broker stays in the chain
MyCustomsInfo\u00ae is not a licensed US customs broker. We do not file with CBP. We do not determine the classification on any specific entry. We prepare the data, surface the candidates, and package the supporting documents. Your licensed broker reviews, applies broker judgment on each candidate, and files the PSC. The regulated activity stays where the regulation puts it. The reason your compliance position stays defensible if CBP audits the refund claim afterward.
The \u00a71641 line we will not cross. The reason your broker stays in the chain and your compliance position stays defensible.
Anonymised real-world scenario
The following is anonymised from typical importer activity. The numbers are realistic but illustrative. Your actual exposure depends on your HTS mix and material composition.
| Importer profile | Mid-size US importer of composite construction products |
| HTS code in use | 7308.20.0035 (derivative aluminum tower structures) |
| Actual product | Composite tower structure with fiberglass body and minimal aluminum joinery fittings |
| BOM aluminum content | Less than 5% (well below the 15% threshold) |
| Entries filed 6 April to 6 May 2026 | 37 |
| Total entered value across the 37 entries | $4,200,000 |
| Section 232 rate paid at filing | 25% (under 9903.82.04) |
| Section 232 duty paid | $1,050,000 |
| Eligible under 9903.82.01 | Yes (BOM and supplier composition certificate support zero applicable metal content) |
| Recoverable through PSC | $1,050,000 |
| Days remaining on earliest PSC window | Approximately 273 days (closes mid-January 2027) |
A single MCI audit cycle surfaces the 37 candidates, packages the documents, and hands the file to the broker. Broker reviews and files PSCs through ACE. Refund is processed by CBP within 60 to 120 days of PSC acceptance.
The 9903.82.01 Refund Assessment service
A focused audit cycle scoped to identify 9903.82.01 candidates in your entries filed since 6 April 2026. Delivered within ten business days of data handover. All fees are fixed. No contingency-linked fees. Per 19 USC \u00a71641 and 19 CFR \u00a7111.36(b).
| Volume band | Implementation Fee | Electronic Audit Fee | Total fixed cost |
|---|---|---|---|
| Up to 1,000 entries | $1,905 | $0.95 per entry | From $2,855 |
| 1,001 to 2,500 entries | $2,540 | $0.95 per entry | From $4,915 |
| 2,501 to 5,000 entries | $3,175 | $0.95 per entry | From $7,925 |
| 5,001 to 10,000 entries | $4,445 | $0.95 per entry | From $13,945 |
| 10,001 plus entries | Bespoke | Bespoke | Quoted on scope |
What you receive
Delivered as a structured candidate file ready for your broker.
- List of every entry filed under a Note 16(c) HTS at a Section 232 rate since 6 April 2026
- For each entry, the BOM and supplier composition declaration reconciled against the HTS classification
- Candidate flag for every entry where the zero-metal qualification is supported by documentation
- Refundable Section 232 duty calculated per entry, plus the PSC deadline date for each
- PSC submission file ready for your broker to review and file
- Summary report with total refundable amount, candidate count and weighted-average PSC window remaining
MyCustomsInfo\u00ae Essentials, Professional and Enterprise subscribers receive a 25% discount on the Implementation Fee. The Electronic Audit Fee is unchanged.
Frequently asked questions
How do I know if any of my entries qualify?+
How long do I have to file the PSC?+
Do you file the PSC for me?+
What if my broker did the original entry under 9903.82.04 at 25%?+
What evidence does CBP want for a 9903.82.01 claim?+
Can I run this assessment myself without MCI?+
Does this affect entries before 6 April 2026?+
How does this fit alongside your standard Historical Audit Module?+
Find out if your entries qualify
Send us your entry volume since 6 April 2026 and your top Note 16(c) HTS codes. We will return a fixed-fee scope and timeline within one business day. Or book a 30-minute call with a Section 232 advisor to walk through the qualification test against your specific HTS mix.
US Regulatory Notice
MyCustomsInfo\u00ae is an independent compliance auditor. It does not conduct customs business as defined under 19 U.S.C. \u00a71641. The specific tariff classification to be applied to any entry of merchandise is to be determined by a licensed Customhouse broker. MyCustomsInfo\u00ae output does not constitute entry preparation, classification advice, or customs broker services. Preparation and filing of Post-Entry Amendments, Post-Summary Corrections, protests, and drawback claims must be performed by a licensed customs broker. US broker records are held in US AWS regions in compliance with 19 C.F.R. \u00a7111.23. Primary authority: CBP HQ H272798 (January 2017). Supporting authority: CBP HQ H350722 (January 2026).