Melt-and-pour and smelt-and-cast on past entries: what was reported, the defaults, and what they cost

What did CBP require to be reported, and from when?

The metal-country fields sit on the entry summary line next to the Section 232 Chapter 99 number. They are not the country of origin. A steel bracket made in Mexico from steel melted in Korea has Mexico as its origin and Korea as its country of melt and pour. CBP has set the requirement in a chain of Cargo Systems Messaging Service (CSMS) messages:

Three details from those messages matter on past lines. For aluminum, CSMS # 65236645 says a filer must report "Y" for the primary or secondary country of smelt and may not report "N" for both; aluminum made only from recycled aluminum reports "Y" for the secondary country of smelt and gives the article's country of origin as that secondary smelt country, and CBP says such aluminum is not common and must be documented. The CSMS for the April 6, 2026 change (# 68253075) told filers to continue reporting the countries of melt and pour and smelt and cast, and said the copper fields would follow by separate message. And CSMS # 68554727 (May 6, 2026) allowed UK-origin steel made by Tata Steel UK and melted and poured in the Netherlands to keep the UK headings until January 1, 2028, with ACE accepting a Netherlands melt country on those headings from May 7, 2026.

When does the reported country change the duty?

The Section 232 metals duty applies by product, from every country, so on most lines the melt or smelt country has no effect on the money. It changes the rate in three places in U.S. note 16 to chapter 99 and its neighbouring headings, as printed in HTSUS 2026 Revision 23:

1. US-made metal. Note 16(e) gives derivative articles a 10 percent heading (9903.82.06, or a 10 percent total under 9903.82.07 for the equipment lists) when at least 85 percent of the steel was melted and poured, or of the aluminum smelted and cast, in the United States. Proclamation 11032 lowered that threshold from 95 percent for entries from June 8, 2026; CSMS # 68253075 shows the 95 percent rule for entries from April 6, 2026. Under the earlier regime, CSMS # 65236374 put derivatives entered from June 4, 2025 that were processed abroad from US-melted steel under heading 9903.81.92 at 0 percent.
2. UK-made metal. Note 16(d) gives UK products 25 percent (9903.82.04) or 15 percent (9903.82.05) instead of 50 or 25 percent, but only where at least 95 percent of the steel was melted and poured, or of the aluminum smelted or most recently cast, in the United Kingdom.
3. Russian aluminum. Clause (8) of Proclamation 11021 keeps the 200 percent duty on aluminum articles and derivatives that are products of Russia, contain any primary aluminum smelted in Russia, or were cast in Russia (9903.85.67 and 9903.85.68). The trigger is the smelt or cast country, not the origin: a Turkish extrusion made from Russian primary aluminum pays 200 percent.

So the cost of a default depends on which way the facts run. A placeholder on a line whose metal was in fact US-made or UK-made overpays. A placeholder, or a guessed country, on a line whose aluminum was in fact Russian underpays.

Worked line: what OTH cost on US-melted steel

A Mexican manufacturer ships moldboard plows, HTS 8432.10.0020, entered on September 15, 2026, entered value $250,000. Plows are on list (c)(x) of note 16, the column 1 general rate is free, and the steel is well over 15 percent of the plow's weight. The supplier buys its steel plate from a US mill and can show, on mill test certificates, that 92 percent of the steel by weight was melted and poured in the United States.

The broker did not have the certificates at filing and reported OTH as the country of melt and pour.

Note 16(b) applies the Section 232 duty in addition to any USMCA rate, so the plow's preference claim does not change the arithmetic, and the line reports 9903.05.90 in place of the Section 301 forced-labor headings under note 52(f)(1). Had the entry been dated May 20, 2026, the threshold would have been 95 percent, the 92 percent share would have failed it, and OTH would have cost nothing.

The reverse case is larger. An aluminum extrusion of heading 7604, a product of Türkiye, entered on September 15, 2026 at $20,000, reported with a non-US placeholder smelt country under the interim rule and filed under 9903.82.02 at 50 percent: $10,000 of Section 232 duty. If the billet came from a Russian smelter, heading 9903.85.67 applied at 200 percent, $40,000, so $30,000 of Section 232 duty was underpaid. And because 9903.85.67 is not one of the headings that note 52(f)(1) exempts from the Section 301 forced-labor duties, the 12.5 percent duty for products of Türkiye under heading 9903.05.79 (in force for entries from July 24, 2026) also applied: 12.5% × $20,000 = $2,500, for $32,500 underpaid in all. The column 1 duty is the same either way.

Where do past entries usually go wrong?

• OTH or a placeholder kept after the facts arrived. CSMS # 65236645 presents the aluminum placeholder as interim and invites a post-summary correction once the smelt or cast country is known. Lines that still carry it a year later were never updated.
• US or UK metal claimed without paper. The US-metal and UK headings are worth between 5 and 40 points of duty against the default heading (a derivative on list (c)(iv) drops from 50 percent under 9903.82.02 to 10 percent under 9903.82.06), so they are the lines most worth supporting before anyone asks. Each needs certificates that tie the mill to the shipment and show the 85 or 95 percent share by weight.
• The wrong threshold for the date. A US-metal claim at 88 percent was valid on entries from June 8, 2026 and not on entries from April 6 to June 7.
• Origin and melt country swapped. A filer that copies country of origin into the melt-and-pour field will report Mexico for Korean steel. That is wrong reporting even when it does not change the duty, and it does change the duty where the copy produces US or UK.
• Russian aluminum hidden in a supply chain. Recycled or secondary aluminum declarations, and casting houses outside Russia using Russian primary aluminum, are the cases where the reported smelt country is most likely to be wrong in the costly direction.
• Copper cable lines from July 30, 2026. Before ACE began rejecting summaries without the copper fields on September 14, 2026, a summary could be accepted without them. Those lines are incomplete rather than mispriced, but they show where the supplier data is missing.

How do you audit a year of lines?

1. Pull every line that carries a Section 232 metals heading (9903.82.xx, and the 9903.81 and 9903.85 headings for earlier entries) with its country of origin, the reported melt-and-pour or smelt-and-cast countries, entry date, entered value and Chapter 99 numbers.
2. Flag the lines where the metal country could change the money: US or UK reported, OTH or a placeholder reported on a UK-origin or Mexican or Canadian line where US steel is common, and any aluminum line with Russia anywhere in the supply chain.
3. For each flagged line, get the mill test certificate or supplier declaration and check the share by weight against the threshold for that entry date.
4. Recompute the heading and the duty, and sort the lines into overpaid, underpaid and unchanged.
5. Correct in both directions: post-summary correction before liquidation, protest within 180 days after it for overpayments, and a prior disclosure for underpayments that are past the PSC route. How long to fix a past entry has every clock.

TariffSense reads the metal-country fields with the rest of each Form 7501 line, checks the 9903.82 heading against the origin, the reported melt or smelt country and the threshold in force on the entry date, and flags lines where a US or UK heading lacks the matching country, where a placeholder sits on a line that could have taken a lower heading, and where an aluminum line's smelt country points to the 200 percent heading. For the full heading method see the Section 232 derivative tier, base and cap; to price one line, use the duty calculator.

What should you ask suppliers for now?

The fields are only as good as the supplier data behind them. Ask each metal supplier, per part number, for the mill or smelter, the country of melt and pour or smelt and cast, the share by weight from each source, and copies of the mill test certificates, and ask to be told when the source changes. Keep them with the entry: 19 CFR 163.4 requires records relating to an entry to be kept for five years from the date of entry, and customs recordkeeping under 19 CFR 163 covers what that includes.

This page describes CBP's published requirements; it is not legal advice. Confirm the reporting on a live entry with your licensed customs broker, and involve counsel before a prior disclosure.