CSMS #68554727: Subheading 9903.82.01 at 0% rate. Retroactive to 06/04/2026. PSC window open.See the recovery assessment →
April 2026 reset the Section 232 rate structure. Every US importer with metal in the supply chain is in scope.
Six rate tiers from 0% to 200%. Copper in scope alongside steel and aluminium. Eighteen Chapter 99 headings. Melt-and-pour and smelt-and-cast origin certificates required. A single-source ACE audit misses the exposure. A six-source audit finds it.
This document defines the scope of a Section 232 compliance engagement. It explains what we audit, how we audit it, what data we ingest and what we deliver. It does not constitute legal advice.
Section 232 is no longer a flat 25% tariff
The April 2026 proclamation replaced the flat 25% with a tiered structure. The rate your entries attract depends on the metal type, the origin, the Annex classification and the metal content percentage. Getting the rate wrong in either direction creates exposure.
One workflow. Three audits. Every entry.
A complete Section 232 audit requires six data sources reconciled against each entry. The ACE entry summary alone cannot reveal whether the origin certificate matches, whether the metal content exemption applies, or whether the SIMA/AIM/CIMA licence data is consistent.
We reconcile every field on the ACE Entry Summary (CBP Form 7501) against the commercial invoice, bill of lading and broker entry worksheet. Where an HTS classification, entered value, country of origin or duty rate does not match the source document, we raise a finding.
For Section 232 entries, Layer 1 also reconciles the SIMA, AIM or CIMA licence data against the declared quantity and value. A mismatch between the licence and the ACE entry is a compliance finding even if the rate was correctly applied.
For every entry line containing steel, aluminium, copper or a derivative article, we verify that the correct Section 232 rate tier was applied. This requires reconciling four additional data sources beyond the ACE entry summary.
Origin tracing: the melt-and-pour certificate (steel) or smelt-and-cast certificate (aluminium, copper) is reconciled against the declared country of origin. Where the metal was refined across multiple countries, the substantial transformation rule determines the origin.
Metal content: for derivative articles, the Bill of Materials determines whether the sub-15% exemption under Note 16(c) applies. Without a BoM documenting the metal weight as a proportion of the finished article, the exemption cannot be substantiated.
Every finding from Layers 1 and 2 is mapped to the applicable CBP correction mechanism. The remaining time window for each route is calculated per entry. Entries closest to deadline closure are prioritised.
9903.82.01 at 0%: CSMS #68554727 created this subheading for goods containing no aluminium, steel or copper. Retroactive to 6 April 2026. The audit identifies qualifying entries and prepares the PSC candidate file.
Section 301 interaction: where Section 232 and Section 301 duties stack on the same entry line, the audit verifies that both rates are correctly applied. Incorrect stacking is a common source of both overpayment and underpayment.
Six sources. Document-first. Every line.
A single-source ACE audit sees the HTS code, the declared origin and the duty paid. It cannot see the Bill of Materials, the supplier metal content declaration, the melt-and-pour certificate or the SIMA/AIM/CIMA licence data. A complete Section 232 audit requires all six sources reconciled against each entry.
FastNet™, our document-extraction engine, ingests all six document types and normalises them into a structured data set. Every field on the entry summary is reconciled against the five supporting documents. Where a field does not match, or where a rate tier does not align with the origin certificate and metal content, a finding is raised.
This approach is deliberately conservative. We do not reclassify. We do not revalue. We reconcile what was declared against what the documents say and what the Section 232 rate schedule requires. The result is a set of findings that are defensible because they are grounded in the importer's own paperwork.
Copper under Section 232: Chapter 74 and derivative articles
The April 2026 proclamation added copper to the Section 232 regime. Chapter 74 now carries Section 232 duty, and derivative articles containing copper are subject to the tiered rate structure. The compliance implications extend well beyond pure copper products.
Chapter 74: Primary Copper
HTS 7401–7404: copper matte, cement copper, blister copper, refined copper and alloys. HTS 7407–7419: bars, rods, wire, plates, foil, tubes, fittings, cloth and other articles. All attract the applicable Section 232 tier rate.
Derivative Articles
Electrical wiring harnesses, heat exchangers, circuit boards, plumbing fittings, brake lines. Any finished good containing copper as a component. The sub-15% metal content exemption under Note 16(c) requires a Bill of Materials documenting the copper weight.
Smelt-and-Cast Certificates
Copper imports require smelt-and-cast origin certificates tracing the copper to the smelter and casting facility. Where copper has been refined across multiple countries, the substantial transformation rule determines the origin for Section 232 purposes.
CIMA Licence Requirements
The Copper Import Monitoring and Analysis (CIMA) system requires a licence prior to entry. CIMA licence data must reconcile to the ACE entry. Discrepancies between licence quantity, commercial invoice and ACE-declared quantity are a common compliance finding.
Six audit findings and the corrective route for each
MCI identifies the finding and quantifies the amount. The recovery action is filed by your licensed customs broker or customs attorney.
| Audit Finding | Recovery or Exposure Route | Filed By |
|---|---|---|
| 9903.82.01 0% rate not applied to qualifying entry | Post-Summary Correction within 300 days of entry | Licensed customs broker |
| Section 232 derivative article not declared on qualifying entry | Prior Disclosure under 19 USC §1592 | Customs attorney |
| Sub-15% metal content exemption available but not claimed | PSC within 300 days, or Protest within 180 days of liquidation | Licensed customs broker |
| Russia-origin 200% rate applied where origin trace shows otherwise | Protest within 180 days of liquidation | Licensed customs broker |
| Section 232 paid on qualifying re-export | Section 232 drawback within 5 years of importation | Licensed broker / drawback specialist |
| Section 301 and Section 232 stacking where only one applies | PSC or Protest depending on liquidation status | Licensed customs broker |
Open Recovery Opportunity
Subheading 9903.82.01 at 0% for entries with no aluminium, steel or copper
CSMS #68554727 / 91 FR 23056 created this subheading with a 0% ad valorem rate for HTS codes subject to Note 16(c) where the goods contain no aluminum, steel or copper. Retroactive to 12:01 AM ET, 06/04/2026.
Approximately six weeks of entries filed between 06/04/2026 and mid-May 2026 carry potential Section 232 duty assessed at 25% on goods that now qualify at 0%. PSC window: 300 days from entry summary, non-extendable.
See the 9903.82.01 Recovery Assessment →What MCI does. What MCI never does.
MyCustomsInfo® operates as an independent compliance auditor under §1641 restrictions. We audit the data. Your licensed customs broker or trade attorney handles every corrective filing.
What MCI Does
- ✓ Ingest and structure all six Section 232 data sources
- ✓ Reconcile ACE entries against origin certificates and licence data
- ✓ Verify the correct rate tier was applied to each entry
- ✓ Identify 9903.82.01 eligibility and sub-15% exemptions
- ✓ Map each finding to PSC, Protest, Drawback or Prior Disclosure
- ✓ Maintain a live Section 232 rate engine updated as CBP publishes
- ✓ Deliver findings in a structured dashboard and PDF report
What MCI Never Does
- ✗ File, prepare or submit any document to CBP
- ✗ File a Post-Summary Correction or Protest on your behalf
- ✗ Determine or confirm an HTS classification
- ✗ File exclusion requests or drawback claims
- ✗ Act as a customs broker, trade attorney or legal adviser
- ✗ Guarantee any classification, valuation or outcome
- ✗ Provide legal advice
Every corrective action sits with your broker or attorney. This separation is the model validated in CBP HQ H272798 (2017) and HQ H350722 (2026). MCI surfaces the finding. Your licensed customs broker determines the corrective action and files the relevant document with CBP. We identify. Your broker acts.
What you receive at the end of each audit cycle
Reconciliation Dashboard
Live, filterable view of every entry, every finding, every rate tier. Drill from summary to entry line. Section 232, 301 and IEEPA in one view.
PDF Audit Report
Formal findings report suitable for board presentation and external audit. Per-metal and per-tier breakdown.
Recovery Schedule
Entry-by-entry quantification of overpayments with the applicable recovery route (PSC, Protest, Drawback) and remaining window.
Exposure Register
Entry-by-entry list of underpayments and compliance gaps requiring corrective action or Prior Disclosure.
Broker Data Pack
Structured data extract formatted for your broker to file PSCs or Protests. Includes ACE entry numbers, rate calculations and supporting evidence.
Rate Audit Trail
Per-entry record of which Section 232 tier, origin certificate and metal content percentage was applied and whether it was correct.
Section 232 compliance engagements typically range from $8,000 to $50,000 per audit cycle for the three-layer scope, depending on entry volume, metal types in scope and the complexity of your supply chain. Full pricing on the US Pricing page.
As an indicative benchmark, importers with metal-containing product lines generating $2M to $15M annual Section 232 duty have historically surfaced 3–6% in audit findings, with the 9903.82.01 recovery opportunity adding a one-time recovery layer.
Section 232 frequently asked questions
Audit your Section 232 exposure before the PSC window closes.
The six-source methodology covers overpayments and underpayments across all six rate tiers. One engagement. One data set. Every finding quantified to the entry line.
30-Minute Section 232 Assessment
Walk through the six-source methodology with a senior compliance analyst. We will show you the dashboard on a demonstration dataset, discuss your metal-containing product lines and scope a tailored engagement.
- 30 minutes, no preparation required
- Demonstration dataset, not your data
- Tailored scope and pricing within 48 hours
Sample Audit on Your Own Entries
We run the full three-layer audit on a sample of your recent ACE entries and return the dashboard, the findings and the recovery schedule within five business days. Available under a signed short-form NDA and Data Processing Agreement.
- NDA and DPA before any data inflow
- Isolated sample audit tenant, AWS KMS encrypted
- Thirty-day retention, then verified destruction