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. 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.
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.
What changed and why it matters
Scope Expansion
- Copper joined steel and aluminum under Chapter 74
- 18 Chapter 99 headings under 9903.82.xx govern rate application
- Annex I-A, I-B and III reference lists define product-specific eligibility
- Russia-origin metal subject to 200% rate under a dedicated heading
New Obligations
- Melt-and-pour certificates required for steel origin
- Smelt-and-cast certificates required for aluminum and copper origin
- SIMA, AIM and CIMA licence data must reconcile to the ACE entry
- FTZ privileged foreign status interacts with rate determination
Key Exemptions and Recovery Routes
- Sub-15% metal content exemption available under Note 16(c) where qualifying conditions are met
- 9903.82.01 at 0% for goods containing no aluminum, steel or copper (CSMS #68554727)
- Section 232 drawback available on subsequent re-export of qualifying goods
Why a single-source ACE audit misses Section 232 exposure
An ACE-only 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.
Other platforms show you ACE data. MyCustomsInfo\u00ae audits the data behind the data.
Subheading 9903.82.01 at 0%
CSMS #68554727 / 91 FR 23056 created subheading 9903.82.01 with a 0% ad valorem rate for HTS codes subject to Note 16(c) where the goods contain no aluminum, steel or copper. This rate applies retroactively 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 exposure on goods that now qualify at 0%. Your licensed customs broker has a Post-Summary Correction route to recover the overpaid duty.
PSC window: 314 days from entry summary, non-extendable. The closer you are to the window closing, the smaller the recoverable population.
Six audit findings and the corrective route for each
MCI identifies the finding and quantifies the amount. The recovery action is filed by the licensed customs broker or customs attorney. Every corrective action sits with the licensed professional.
| Audit Finding | Recovery or Exposure Route | Filed By |
|---|---|---|
| 9903.82.01 0% rate not applied to qualifying entry | Post-Summary Correction within 314 days of entry summary | Licensed customs broker |
| Section 232 derivative article not declared on a qualifying entry | Prior Disclosure under 19 USC 1592 | Customs attorney |
| Sub-15% metal content exemption available but not claimed | PSC within 314 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 claim within 5 years of importation | Licensed customs broker or drawback specialist |
| Section 301 and Section 232 duties stacking where only one applies | PSC or Protest depending on liquidation status | Licensed customs broker |
Where Section 232 and Section 301 meet
Section 301 tariffs apply to Chinese-origin goods under Lists 1 through 4A at rates between 25% and 100%. Where Section 232 and Section 301 fall on the same entry line, the duties stack. The effective rate frequently lands between 30% and 50% before base HTS duty is added.
Overpayment Scenarios
- $Section 301 applied to a product that has been excluded from the relevant list
- $Section 232 applied at the wrong tier due to incorrect origin or metal content
- $Both duties applied where goods qualify for a tariff exclusion
Underpayment Scenarios
- !Derivative article not declared on a qualifying entry
- !Incorrect Section 301 list assignment
- !Melt-and-pour or smelt-and-cast origin missed
What MCI does. What MCI never does.
What MCI Does
- Ingest and structure shipping documents via FastNet™
- Reconcile declared values against all six source documents
- Identify Section 232 and 301 discrepancies per entry line
- Quantify overpaid and underpaid duty exposure
- Deliver findings in a structured dashboard and PDF report
- Provide the data pack for broker-filed corrections
- Maintain a live Section 232 rate engine updated as CBP publishes
What MCI Never Does
- File, prepare or submit any document to CBP
- Determine or confirm an HTS classification
- File a Protest, PSC or Prior Disclosure
- Prepare or file a drawback claim
- Act as, or hold itself out as, a customs broker
- Provide legal advice
- Guarantee any classification, valuation or outcome
Compliance boundary. MyCustomsInfo\u00ae maintains a live Section 232 rate engine that ingests CBP Federal Register notices, CSMS messages, and Annex updates as they are published. The rate in force on the date of entry is applied to every declaration audited, not the rate at engagement start. MCI surfaces the finding. Your licensed customs broker determines the corrective action and files the relevant document with CBP. This separation is the model validated in CBP HQ H272798 (2017) and HQ H350722 (2026).
Section 232 Frequently Asked Questions
Related US Compliance Resources
9903.82.01 Recovery Assessment
Focused, time-boxed engagement for the 0% rate recovery window.
Learn moreUS Audit Scope
Three-layer audit model: original submission, IEEPA refund, Section 232 and 301 exposure.
Learn moreIEEPA Tariff Compliance
IEEPA protest and refund recovery for duties paid under presidential tariff authority.
Learn moreAudit 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.