Section 232 Steel/Aluminum Content Reporting "Guidance"

Mar. 30, 2026
By: Chaney A. Finn

The Section 232 saga continues as many of the same underlying concerns remain unchanged from the last guidance CBP issued for content reporting purposes. U.S. Customs and Border Protection’s Base Metals Center of Excellence and Expertise (CEE) provided its latest informal guidance on calculating metal content for Section 232 tariffs, adding new direction on iron. Importantly, CBP has noted that the guidance is “advisory only and not binding,” stating that binding determinations require Binding Ruling requests that are submitted via the eRulings program on cbp.gov.

Based on the latest informal, advisory and non-binding guidance, CBP indicated that importers should assess iron content similarly to steel and aluminum, though some forms, like cast or pig iron, may fall outside the tariffs. The update also informally advises importers that they should not reclassify steel products as non-tariff iron based on chemistry. 

The non-binding guidance outlines key timing rules for iron-related duties and advises that importers can allocate shared costs, such as labor and packaging, based on value ratios. However, the legal status of this guidance is questionable. First, CBP itself has noted that it is not binding, is advisory, and is informal. Moreover, the original 232 investigations focused on steel and aluminum and did not address iron, which is a distinct material. As such, there is a question regarding the authority to impose 232 duties on iron. Also, the Base Metal Center’s approach of requiring the importer to determine the purchase price for non-metal components in a larger assembly is inconsistent with the requirement that import values not be based on arbitrary or fictional prices. Litigation has been undertaken with respect to a previous iteration of this informal guidance. Thus, importers may choose to protest any 232 calculation-related rate advance from Customs.

Trade groups request that CBP issue formal guidance for steel and aluminum valuation, even filing a lawsuit to challenge the informal guidance on procedural grounds. Importers may have experienced inconsistent enforcement as a result of the guidance issued, in the form of CBP requests for information (CF28) or notices of action (CF29), which has led to litigation to resolve the issue once and for all.

Should you have any questions about steel and aluminum content reporting, Section 232, or any other trade-related questions, do not hesitate to contact any attorney at Barnes Richardson and Colburn, LLP.