CBP has issued guidance to the trade clarifying how Section 232 content value is determined, addressing industry confusion around which costs may and may not be deducted from customs value. Please see the full guidance attached to this newsletter.
Chapter 72, Steel Articles
Articles classified in chapter 72 are considered 100% steel. Section 232 duties are assessed on the full entered value. Costs such as manufacturing, labor, machining, coatings or fabrication cannot be deducted.
Chapter 73, Chapter 76 and Articles Classified Elsewhere
If an article is wholly of steel or wholly of aluminum, Section 232 duties apply to the full entered value.
If an article contains non-steel or non-aluminum components, Section 232 duties apply only to the value of the steel or aluminum content.
The steel or aluminum content value is generally calculated as the total entered value minus the cost to the importer of the non-steel or non-aluminum components. Non-metal content refers only to distinct parts or components, not to labor, fabrication, coatings, machining or similar costs.
If the value of the steel or aluminum content cannot be determined, CBP requires Section 232 duties to be assessed on the total entered value, reported on a single entry summary line.
Treatments, Coatings and Shared Costs
Surface treatments such as galvanizing and anodizing are considered integral to the metal article and are not separate components. Paint, lacquer and coatings are also not deductible.
Costs that apply to both metal and non-metal content, such as packaging, should be reasonably apportioned.
Copper and Copper Alloys
CBP applies the same approach to copper and copper alloys, including brass. These articles are subject to Section 232 duties, and CBP does not permit breaking down the chemical composition to isolate copper value. Alloying elements are not deducted.
Documentation Expectations
Importers must maintain documentation sufficient to support the claimed steel, aluminum or copper content value if CBP requests substantiation.
Practical Example
If an importer pays $100 for a finished window and $20 of that value is attributable to non-steel components such as glass, the entered value remains $100. The entry may be reported with $20 as non-steel content and $80 as steel content, with Section 232 duties assessed on the $80 steel portion.
CBP has not issued new guidance beyond this position, and importers should continue to monitor Cargo Systems Messaging Service
(CSMS) messages, trade remedy FAQs and CBP rulings for updates.
ISPM 15 Requirements for Wood Packaging Material (WPM)
All wood packaging material entering or transiting the United States must be Identity Security Posture Management (ISPM) 15 compliant. This means WPM must be pest-free, debarked, properly heat-treated or fumigated, and clearly marked with a valid ISPM 15 stamp. Shipments with noncompliant WPM may be refused entry.
ISPM 15 applies to common packaging materials, including pallets, crates, boxes, bins, reels, drums, load boards, dunnage and similar items. Import requirements for WPM and other agricultural commodities can be referenced in the United States Department of Agriculture’s (USDA’s) Agricultural Commodity Import Requirements (ACIR) database.
Important Update on ISPM 15 Markings
USDA Animal and Plant Health Inspection Service (APHIS) has confirmed that the temporary enforcement pause related to the hyphen in ISPM 15 markings ends Dec. 31, 2025. From March through Dec. 31, 2025, CBP and APHIS did not take action on shipments missing the hyphen after the two-letter country code. Beginning Jan. 1, 2026, this requirement will again be enforced. All other ISPM 15 requirements have remained in effect and continue to be enforced.
Importers, suppliers and WPM manufacturers should use this transition period to ensure full compliance with ISPM 15 Annex 2, including the required hyphen between the country code and producer code.
What Inspectors Look For
CBP and APHIS inspectors verify the presence of a valid ISPM 15 mark and inspect WPM for signs of pests. A compliant ISPM 15 mark includes:
- The International Plant Protection Convention (IPPC) logo
- A two-letter country code
- A unique producer or facility code
- The treatment type, either heat treatment (HT) or methyl bromide (MB)
Ensuring WPM markings are accurate and complete helps prevent delays, refusals and costly rework at the port.
