Copper 232 Coverage Issued Through Customs

Jul. 31, 2025
By: Hannah B. Kreinik

Yesterday we wrote about new 232 duties on copper without being sure what tariff provisions would be covered by the new tariffs. Today we have a list of those entries and more guidance on implementation. Be careful what you wish for.

On July 31, 2025 Customs issued CSMS #65794272 which provides guidance on the administration of the copper derivative duties. The guidance includes a complete annex with all covered subheadings, including but not limited to, products such as wiring, copper powder, copper tubing and pipes, sheets, foil, nails, rods, and household articles. Please see the complete list here.

The guidance directs brokers and importers to report goods subject to the copper duties under tariff provision 9903.78.01. The CSMS also states that the value of the copper content subject to the proclamation should be assessed using the Customs Valuation Agreement’s “price paid or payable.” This means that the value of copper content will be the price paid for the copper material content by the buyer to the seller (normally shown on the invoice).

The entry information for the non-copper content and the copper content of the goods should be reported on individual entry lines. The non-copper content and goods listed on the annex that do not contain copper should report tariff provision 9903.78.02 to avoid copper 232 duty. Importers and brokers should be prepared to substantiate entry claims using supporting documents like the good’s invoices, bill of materials, and accounting documentation.

The CSMS message specifically states that “for imported articles composed only of copper, the dutiable value of the copper content is the total entered value.”

Barnes, Richardson & Colburn attorneys continue to keep you informed about developing issues. Please feel free to contact us about your specific copper products.