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Section 232 HTS Update Now Live

To Our Valued Partners,

Following our recent advisory sent on the April 6, 2026, regarding the recent Section 232 changes, U.S. Customs and Border Protection has now issued CSMS #68290408 (HSU 2607) confirming that the updated tariff structure is now reflected in the Harmonized Tariff Schedule.

This update is important because it does not just change rates, it changes how tariffs are reported and applied in your systems.

These updates support the Section 232 changes that became effective April 6, 2026, at 12:01 AM ET.

WHAT CHANGED

  • The HTS system has been officially updated by USITC
  • Old Section 232 exemption code series, including 9903.80 series and 9903.81 series, were terminated and deleted
  • New Chapter 99 headings were added and must now be used where applicable
  • Duty rates were updated across steel, aluminum, and copper categories
  • Government agency flags (EPA/FDA) were also updated

KEY UPDATE: CHAPTER 99 WAS RESTRUCTURED

This is the most important takeaway.

The old Section 232 structure under:

  • 9903.80 series
  • 9903.81 series

has been removed and replaced

It is now replaced with:

  • 9903.82.02 through 9903.82.17

These are the new Chapter 99 headings that may now apply to covered entries.

WHY THIS MATTERS

This is not just a rate change.

If your system or filing process still references deleted headings, those references should be reviewed and updated immediately.

WHAT THE NEW STRUCTURE DOES

The new 9903.82 series organizes tariffs based on:

  • Type of product
  • Type of metal (steel, aluminum, copper)
  • Country of origin
  • Metal composition

Each covered imported article should fall under only one of these headings.

UPDATED DUTY STRUCTURE 

50% Duty

  • Applies to many aluminum, steel, and certain copper products
  • Based on Annex I-A
  • Applies generally, unless a lower rate applies under the UK or qualifying U.S.-content provisions.

25% Duty: Applies to certain copper articles and certain aluminum and steel derivative articles listed in Annex I-B.

Reduced Rates (Special Cases)

United Kingdom: Reduced UK rates apply only where the applicable aluminum is composed entirely of aluminum that was smelted or most recently cast in the United Kingdom, or the applicable steel is composed entirely of steel that was melted and poured in the United Kingdom.

United States Content: 10% rates apply where the applicable aluminum, steel, or copper content is composed entirely of qualifying U.S.-processed metal, as described in the proclamation.

LOW METAL CONTENT RULE (IMPORTANT)

A special provision exists under 9903.82.03: For listed provisions outside Chapters 72, 73, 74, and 76, heading 9903.82.03 applies where the weight of the applicable metal is less than 15% of the weight of the imported article.

This is not automatic.

You must: Maintain documentation supporting the claimed metal-weight calculation.

FULL VALUE DUTY RULE 

Duties now apply to the full value of the product, not just the metal portion.

This applies even if:

  • Metal is only one component of the product

This is one of the biggest cost impacts from the update.

ADDITIONAL IMPORTANT UPDATES

No Double Tariffs:


The new headings are mutually exclusive, so a covered imported article will be subject to no more than one of these headings.

Foreign Trade Zone (FTZ) Impact

  • Goods admitted into a U.S. FTZ on or after April 6, 2026, that are subject to duties under this proclamation, and not eligible for domestic status, may be admitted only under privileged foreign status.

Drawback

  • The proclamation allows manufacturing drawback only for articles meeting specific conditions and says no other drawback claims are available except as provided.

Russia-Specific Provisions

  • Separate tariff rules still apply
  • Certain products fall under specific Russia-related HTS codes
  • Aluminum tied to Russia may still be subject to 200% duties under separate measures

EPA and FDA Flag Updates

  • EPA removed and added multiple HTS flags
  • FDA changed tariff flag FD3 to FD2 for HTS 3001.90.0150.

WHAT YOU NEED TO DO

  • Review all affected HTS classifications
  • Update any system or internal references to old 9903.80/81 series codes
  • Confirm correct 9903.82 code is being used (where applicable)
  • Validate metal content calculations where applicable
  • Coordinate with your broker on updated filing requirements
  • Review impacted shipments entered on or after April 6

WHY THIS UPDATE IS IMPORTANT

The biggest risk is not the rate change; it is using outdated HTS logic that no longer exists.

QUESTIONS?

If you have questions about how this update may affect your shipments, I am here to help.

833-782-7628 Ext. 1

RESOURCES

We encourage you to review the official government documents for full details:

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