CBP Section 232 Metal Content Valuation Guidance Summary

In early December 2025 the CBP Base Metals Center for Excellence (BM CEE) provided the following verbal guidance at the Port of Newark’s quarterly area brokerage community meeting regarding the treatment of Section 232 duties and how metal and non-metal content values are to be calculated. The following is a summary of that guidance and an example of mixed article valuation provided by CBP.

1. Steel Articles of Chapter 72

• 100% Steel Value: Articles of Chapter 72 are treated as products of 100% steel
• Dutiable Value: Section 232 duty is assessed on the full entered value of the article
• No Subtractions: Costs for manufacturing, labor, coating, etc. are not subtracted

1. Articles of Chapter 73 and Elsewhere

Products Wholly of Steel

• 100% Value: Articles of Chapter 73 wholly of steel are so treated
• Dutiable Value: Section 232 duty is assessed on the full entered value of the article
• No Subtractions: Costs for manufacturing, labor, coating, etc. are not subtracted

Non-Wholly of Steel (Mixed Articles)

If the article contains non-steel or components, the Section 232 duty is assessed only on the steel content.

Dutiable Value: Section 232 duty is assessed on the steel content value of what the US importer paid for that content

Calculated As: Entered Value minus Cost of the Non-Steel Component

What is NOT Subtracted: 

“Non-Steel Content” does not refer to costs for fabrication, machining, labor, coating, paint, lacquer, or other surface treatments (e.g., galvanizing, anodizing). These costs are considered integral and cannot be deducted

Undeterminable Value: If the steel content value cannot be determined, the duty must be reported using the total entered value on a single-entry summary line

Apportionment: Costs attributable to both (e.g., packaging) should be apportioned between the content subject to duty and the content not subject to duty

Documentation

Importers must have “documentation sufficient to support the importer’s claimed steel/aluminum/copper and its alloys content value” if CBP requests it.

The core principle is that manufacturing, labor, and surface treatment costs are not deductible when determining the content value for Section 232 duty, even for mixed articles. Subtractions are only allowed for the cost of a separate, non-base-metal part or component.

1. Articles of Chapter 76 and Elsewhere

Products Wholly of Aluminum

• 100% Value: Articles of Chapter 76 wholly of aluminum are so treated
• Dutiable Value: Section 232 duty is assessed on the full entered value of the article
• No Subtractions: Costs for manufacturing, labor, coating, etc. are not subtracted

Non-Wholly of Aluminum (Mixed Articles)

If the article contains non-Aluminum or components, the Section 232 duty is assessed only on the Aluminum content.

Dutiable Value: Section 232 duty is assessed on the Aluminum content value of what the US importer paid for that content

Calculated As: Entered Value minus Cost of the Non-Aluminum Component

What is NOT Subtracted: 

“Non-Aluminum Content” does not refer to costs for fabrication, machining, labor, coating, paint, lacquer, or other surface treatments (e.g., galvanizing, anodizing). These costs are considered integral and cannot be deducted.

Undeterminable Value: If the Aluminum content value cannot be determined, the duty must be reported using the total entered value on a single-entry summary line

Apportionment: Costs attributable to both (e.g., packaging) should be apportioned between the content subject to duty and the content not subject to duty

Documentation

Importers must have “documentation sufficient to support the importer’s claimed steel/aluminum/copper and its alloys content value” if CBP requests it.

The core principle is that manufacturing, labor, and surface treatment costs are not deductible when determining the content value for Section 232 duty, even for mixed articles. Subtractions are only allowed for the cost of a separate, non-base-metal part or component.

1. Articles of Chapter 74 (Copper and Its Alloys) and Elsewhere

Products of Copper and Its Alloys (e.g. Brass)

No Chemical Breakdown: The chemistry of the imported article is not broken down to calculate a copper-only value; the value of alloying elements is not deducted

Articles of Chapter 74 (Copper and Its Alloys) and Elsewhere

Products Solely of Copper and Its Alloys (e.g. Brass)

• 100% Value: Articles of Chapter 74 wholly of copper or copper alloys are so treated
• Dutiable Value: Section 232 duty is assessed on the full entered value of the article
• No Subtractions: Costs for manufacturing, labor, coating, etc. are not subtracted
  No Chemical Breakdown: The chemistry of the imported article is not broken down to calculate a copper-only value; the value of alloying elements is not deducted

Articles of Chapter 74 (Copper and Its Alloys) and Elsewhere

Non-Wholly of Copper and Its Alloys (Mixed Articles)

If the article contains non-copper (or its alloys) or components, the Section 232 duty is assessed only on the copper / copper alloy content

Dutiable Value: Section 232 duty is assessed on the copper / copper alloy content value of what the US importer paid for that content

Calculated As: Entered Value minus Cost of the Non-Copper / Copper Alloy Components

What is NOT Subtracted: 

“Non-Copper / Copper Alloy Content” does not refer to costs for fabrication, machining, labor, coating, paint, lacquer, or other surface treatments (e.g., galvanizing, anodizing). These costs are considered integral and cannot be deducted.

Undeterminable Value: If the copper / copper alloy content value cannot be determined, the duty must be reported using the total entered value on a single-entry summary line

Apportionment: Costs attributable to both (e.g., packaging) should be apportioned between the content subject to duty and the content not subject to duty

Documentation

Importers must have “documentation sufficient to support the importer’s claimed steel/aluminum/copper and its alloys content value” if CBP requests it.

The core principle is that manufacturing, labor, and surface treatment costs are not deductible when determining the content value for Section 232 duty, even for mixed articles. Subtractions are only allowed for the cost of a separate, non-base-metal part or component.

CBP Section 232 Contents Value example.

CBP provided the following example for content value determination.

Take a window for example—

• What did the importer of record pay for the finished windows?
• If the windows have non-steel components/parts like glass, what was the cost of that to the importer? • Minus the cost to the importer of the non-steel parts from the total window cost to the importer and that equals the Section 232 steel content value.

So, if—

• The importer paid $100 for the window.
• $20 of the cost is attributable to glass or other component/parts.
• The entered value of the window is $100. It may be separated into two lines. A non-steel content line of $20 and a steel content line of $80.

What is instructive in the example is the determination of the steel value was simply the total product value less the non-steel contents. The steel value determination had nothing to do with the cost or price of the steel itself, simply the costs of the non-steel items subtracted from the total product price.