- Country: United States
- Explainer
- Topic: Section 232
- Topic: Duty stack
- Topic: Post-entry audit
- Topic: Valuation
- Topic: Refunds
Section 232 on full value from April 6: which past entries used the wrong base?
Published · Updated
This page describes the rules in force on . When they change, we publish a new page and link it from here.
Short answer
For goods entered on or after 12:01 a.m. eastern daylight time on April 6, 2026, Proclamation 11021 applies the Section 232 aluminum, steel and copper duties to the full customs value of the article, regardless of metal content, at 50, 25, 15 or 10 percent depending on the annex and origin. Before that, from June 4, 2025, the steel and aluminum duties on chapter 73 and chapter 76 articles and on the derivatives added in 2025 were charged only on the value of the metal content, with the rest of the article reported on its own line. An entry on either side of the date filed under the other side's method used the wrong base: a split line after April 5 underpays, a full-value line before April 6 overpays.
TariffSense checks every line of your filed entries against the measures in force on the entry date.
What changed on April 6, 2026?
The base of the duty changed. Clause (1) of Proclamation 11021, signed April 2, 2026, says that for goods entered for consumption or withdrawn from warehouse on or after 12:01 a.m. eastern daylight time on April 6, 2026, the Section 232 duty on aluminum, steel and copper articles and their derivatives "shall apply to the full customs value of the imported product, regardless of metal content." CBP's filing guidance followed on April 3 (CSMS # 68253075), and HTSUS Revision 5 printed the new U.S. note 16 and headings 9903.82.02 onward.
| Entries June 4, 2025 to April 5, 2026 | Entries from April 6, 2026 | |
|---|---|---|
| Base for steel and aluminum articles | Value of the metal content for articles of chapters 73 and 76 and for the derivatives added in 2025 (9903.81.91, 9903.85.08); full value for chapter 72 steel and for the older derivatives outside chapters 73 and 76 under 9903.81.89 (CSMS # 65236374; HTSUS Rev. 4, note 16(i), (k), (n) and note 19) | Full customs value (Proclamation 11021, clause 1) |
| Lines on the 7501 | Two lines where the metal content was worth less than the entered value: non-metal content, then metal content with the Chapter 99 number | One line |
| Example headings, derivative steel | 9903.81.89 and 9903.81.90 (content base for chapter 73 goods), 9903.81.91 (new derivatives outside chapter 73, content base), at 50% | 9903.82.02 at 50% (Annex I-A, note 16(c)(i) to (v)); 9903.82.09 at 25% (Annex I-B, note 16(c)(vi) to (viii) and (xi)) |
| Low-metal articles | Duty on the metal content, however small | No duty where a listed article outside chapters 72, 73, 74 and 76 is under 15% metal by weight (heading 9903.82.03) |
| Other duties on the non-metal part | Reported on the non-metal line, for example the Section 122 surcharge from February 24, 2026 | None separately: the whole line is a Section 232 line |
| Drawback | Not available for the steel duties (CSMS # 65236374) | Manufacturing drawback available for the Proclamation 11021 duties (CSMS # 68253075) |
The rates moved too. Proclamation 11021 sets 50 percent for the Annex I-A articles, 25 percent for the copper articles and the aluminum and steel derivatives listed in Annex I-B, 25 and 15 percent for qualifying United Kingdom goods, 10 percent for derivatives made with U.S.-melted steel or U.S.-smelted aluminum or copper, and a floor rule for Annex III derivatives until December 31, 2027. Working out the tier for a given code and origin is a separate method, covered on the Section 232 derivative tier, base and cap. This page is about the base and the date.
Why do wrong-base entries happen?
Because the old method was hard to unlearn. For ten months brokers split derivative lines into a metal-content line and a non-metal line, with a second quantity in kilograms on the Chapter 99 number, as CSMS # 65236374 required. Supplier invoices were built to state metal content and value. Product masters stored a "steel content value" per SKU. When the base changed, a filer who kept the template kept the split.
The reverse also happened before April 6. CBP's 2025 guidance said that if the value of the steel content was the same as the entered value, or was unknown, the duty went on the entire entered value on one line. Importers who did not get content values from suppliers paid on full value for months. That was the rule, not an error, but where the content value can now be documented it is worth checking whether the line can be corrected while the entry is still open.
Worked lines on each side of the date
Stainless steel cookware with glass lids and phenolic handles, HTS 7323.93.00 (general rate 2%), product of Vietnam. Each shipment has an entered value of $40,000, of which the steel is worth $28,000. Subheading 7323.93.00 was a derivative steel article under note 16(m) and heading 9903.81.90 in HTSUS Revision 4, and is in note 16(c)(vii), heading 9903.82.09, from Revision 5. Both entry dates fall inside the Section 122 surcharge window (February 24 to July 23, 2026), which is why the surcharge appears. The products are illustrative; fees are left out.
Entered March 16, 2026: content base
Two lines, as CSMS # 65236374 required. The non-steel line carries the Section 122 surcharge under 9903.03.01; the steel line is exempt from it under 9903.03.06 (note 2(aa)(v)(b) in Revision 4).
| Line | Value | General rate 2% | Section 122, 9903.03.01, 10% | Section 232, 9903.81.90, 50% | Line duty |
|---|---|---|---|---|---|
| 1, non-steel content | $12,000 | $240 | $1,200 | $1,440 | |
| 2, steel content | $28,000 | $560 | exempt | $14,000 | $14,560 |
| Entry | $40,000 | $16,000 |
Entered April 20, 2026: full-value base
One line. Heading 9903.82.09 charges 25 percent of the full value, and the Section 122 surcharge does not apply to a Section 232 line (Proclamation 11012, clause 4; note 2(aa)(v)(1) in Revision 5).
| Line | Value | General rate 2% | Section 122 | Section 232, 9903.82.09, 25% | Line duty |
|---|---|---|---|---|---|
| 1 | $40,000 | $800 | not applicable | $10,000 | $10,800 |
For this product the change lowered the duty, because the rate fell from 50 to 25 percent while the base widened. For an Annex I-A derivative, still at 50 percent, the same change raises it.
The two wrong-base findings
| Finding | What was filed | Duty filed | Correct duty | Difference |
|---|---|---|---|---|
| Old method after April 5 | April 20 entry split: steel line 25% × $28,000 = $7,000; non-steel line with Section 122 $1,200; general rate $800 | $9,000 | $10,800 | Underpaid $1,800 |
| New method before April 6 | March 16 entry on one line: 50% × $40,000 = $20,000; general rate $800; no Section 122 | $20,800 | $16,000 | Overpaid $4,800 |
The second finding needs care: it is an overpayment only if the steel content value can be documented. Without it, the 2025 guidance put the duty on the full entered value, and the line was right as filed.
Which other entries carry a wrong base?
- Entries filed in the days around April 6. Cargo released under a pre-April entry template and summarised after the change, or the reverse, carries the other side's method. Sort by entry date, not by release or invoice date.
- Low-metal derivatives from April 6. A listed article outside chapters 72, 73, 74 and 76 with less than 15 percent metal by weight belongs under 9903.82.03 with no Section 232 duty. Under the old method it paid on its small metal content; a filer who moved it to full value without checking weight pays on the whole article. CBP's guidance asks for the aggregate metal weight in kilograms as a second quantity on 9903.82.03, so the weight should be on the entry.
- Multi-metal articles. From April 6 an article listed under more than one metal pays once (Proclamation 11021, clause 9). A line with two Section 232 headings has double-charged.
- The knock-on to later layers. From July 24, 2026 a line under 9903.82.02 or 9903.82.04 to 9903.82.26 is exempt from the Section 301 forced-labor duty (heading 9903.05.90). A line that should have been under 9903.82.03 is not, so getting the 232 heading right decides the next layer too; see what the Section 301 forced-labor duty adds to an entry line.
How do you find and fix them?
- Pull every line with a Section 232 heading from June 4, 2025 onward, with entry date, chapter 1 to 97 number, every Chapter 99 number, entered value, metal content value where reported and the second quantity.
- Group lines that share an entry and a tariff number. Two lines with the same code, one with zero quantity and a 9903.81 number, are a content split.
- Test the method against the entry date. A split on an entry dated April 6, 2026 or later is a wrong-base underpayment. A full-value line before that date on a chapter 73 or 76 article or a 2025 derivative (9903.81.91, 9903.85.08), with a documentable content value, is a possible overpayment.
- Check the heading and rate for the post-April line from note 16 and the origin, and the 15 percent weight rule for articles outside chapters 72, 73, 74 and 76.
- Recompute each line, including the Section 122 surcharge on the non-metal line before April 6 and its absence after.
- Route each finding by entry status.
| Entry status (as of November 11, 2026) | Route | Deadline |
|---|---|---|
| Unliquidated, entered January 15, 2026 or later | Post-summary correction | 300 days from entry or 15 days before scheduled liquidation, whichever is earlier (91 FR 41053) |
| Liquidated in the last 180 days | Protest | 180 days after liquidation (19 U.S.C. 1514) |
| Liquidated more than 180 days ago | Generally closed for overpayments | |
| Any status, underpayment | Correction before liquidation, or prior disclosure | See prior disclosure after you find an underpayment |
For the worked entries, the March 16, 2026 entry reaches 300 days on January 10, 2027 and the April 20 entry on February 14, 2027. Pre-April entries are running out of correction time: every entry from June 2025 through mid-January 2026 is already past 300 days, so for those only a protest after liquidation remains. The full deadline picture is on how long you have to fix a past entry.
A post-entry audit reads the 7501 lines, pairs the split lines, tests the method against each entry date and flags both kinds of wrong base. To see the Section 232 layer for one code, origin and date, use the duty calculator. The wider set of stack errors is on why your entry shows the wrong duty stack, and where this fits in a full review on post-entry customs audit of Form 7501.
Sources
- Proclamation 11021, Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States, 91 FR 18201 (April 9, 2026) (govinfo.gov, checked )
- CBP CSMS # 68253075, Guidance: Section 232 Duties on Imports of Aluminum, Steel, and Copper (April 3, 2026) (content.govdelivery.com, checked )
- CBP CSMS # 65236374, Updated Guidance: Import Duties on Imports of Steel and Steel Derivative Products (June 3, 2025) (content.govdelivery.com, checked )
- USITC, Harmonized Tariff Schedule, Chapter 99, Revision 4 (2026), U.S. notes 2(aa) and 16 before April 6, 2026 (hts.usitc.gov, checked )
- USITC, Harmonized Tariff Schedule, Chapter 99, Revision 5 (2026), first printing of the new U.S. note 16 (hts.usitc.gov, checked )
- USITC, Harmonized Tariff Schedule, Chapter 99, Revision 23 (2026), U.S. notes 16 and 52 (hts.usitc.gov, checked )
- Proclamation 11012, Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems, 91 FR 9339 (February 25, 2026) (govinfo.gov, checked )
- CBP, Modification and Clarification of the National Customs Automation Program Test Regarding Post-Summary Corrections, 91 FR 41053 (July 6, 2026) (federalregister.gov, checked )
- Updated : Re-checked every source; rates, caps and deadlines updated.