CUSTOMS COMPLIANCE | 2026-10-04

Where Was the Metal Made? Section 232 Melt-and-Pour and Smelt-and-Cast Reporting for Steel and Aluminum Importers

For steel and aluminum imports, CBP now asks not only where a product was made, but where its metal was first melted and poured or smelted and cast. Those answers can determine whether an exclusion applies — and an “unknown” can trigger the highest Section 232 rate on the books.

For most imported goods, country of origin is the country where the product was last substantially transformed. Steel and aluminum are different. Because the Section 232 national-security tariffs and related monitoring programs focus on where metal is actually produced, CBP requires importers to rep

A steel product can be fabricated in one country from steel melted in another. For Section 232 purposes, the second country increasingly matters as much as the first.

Why Section 232 Looks Behind the Product

Section 232 of the Trade Expansion Act of 1962 authorizes the President to adjust imports that threaten to impair national security. The steel and aluminum tariffs imposed under that authority are aimed at the production of the metal itself — the furnaces and smelters where steel and aluminum are made. A tariff based only on where a finished product was last processed could be avoided by melting steel or smelting aluminum in one country and performing downstream processing in another. Melt-and-pour and smelt-and-cast reporting lets the government see where the metal was actually produced, and lets tariff measures be tied to that fact.

A Brief History of the Measures

The current steel and aluminum tariffs trace to proclamations issued in March 2018, which imposed Section 232 duties of 25 percent on steel and 10 percent on aluminum imports. Since then, the measures have been modified many times — through country-specific arrangements and exemptions, product exclusion processes, expansions to cover derivative products, and changes in rates. The 2025 changes broadened coverage of derivative products and changed how duties are calculated on them. Because the measures change frequently, importers should confirm the rules in effect on the date of each entry rather than relying on prior practice.

Section 232 Duties Are Not IEEPA Duties

Many importers are now pursuing refunds of tariffs imposed under the International Emergency Economic Powers Act, which the Supreme Court invalidated in February 2026. Section 232 duties rest on a different statute and were not affected by that decision. An entry that carried both IEEPA tariffs and Section 232 duties may support a refund of the IEEPA portion, but the Section 232 portion remains owed. Accurate melt-and-pour, smelt-and-cast, and metal-content reporting therefore matters both for Section 232 compliance and for cleanly separating refundable IEEPA amounts from non-refundable Section 232 amounts when entries are reviewed.

Steel: Country of Melt and Pour

CBP requires importers to report on the entry summary (CBP Form 7501) the country of melt and pour for imports under the steel HTS classifications that are subject to the Department of Commerce’s steel import licensing program and, where applicable, the Section 232 steel measures.

The country of melt and pour is the original location where the raw steel was first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. That first solid shape can be a semi-finished product — such as a slab, billet, or ingot — or a finished steel mill product. Subsequent rolling, drawing, coating, cutting, or fabrication in another country does not change the country of melt and pour.

A new requirement to disclose the steel country of melt and pour through the Importer’s Additional Declaration — Type Code 08, Steel Melt and Pour Country Detail, on the entry summary’s 54 record — became effective November 21, 2024. Brokers and importers transmitting entries must therefore have melt-and-pour data available at the time of filing.

Aluminum: Countries of Smelt and Cast

For aluminum, CBP requires importers to report on the entry summary the countries of smelt and cast for imports under the aluminum HTS classifications subject to Commerce’s aluminum import licensing program and, where applicable, the Section 232 aluminum measures. “Smelt” refers to where primary aluminum was produced; “cast” refers to where the aluminum was cast into a form. Both data points are reported because aluminum can be smelted in one country and cast or recast in another.

Effective June 28, 2025, CBP addressed derivative aluminum products whose smelt or cast country the importer does not know. For imports of derivative aluminum subject to the Section 232 measures, an importer that does not know the country of smelt and/or cast must report “unknown” in place of the ISO country code. When “unknown” is reported, the importer must also report HTS subheading 9903.85.67 or 9903.85.68, as applicable, and the entry is assessed the 200 percent Section 232 duty that applies to imports of aluminum from Russia.

That rule turns missing supplier data into a direct and severe cost. An importer that cannot document where its aluminum was smelted and cast is treated, for duty purposes, as if the metal came from the most heavily tariffed source.

Derivative Products and Metal Content

Section 232 duties apply not only to basic steel and aluminum mill products but also to many derivative products — goods made of or containing steel or aluminum that are covered by the Section 232 proclamations. Under CBP guidance, for derivative articles that are not wholly made of steel or aluminum, the Section 232 duty is assessed on the value of the steel or aluminum content of the article rather than the full value of the article, provided the entry is reported correctly. CBP’s guidance tied this content-based approach to the June 4, 2025 changes to the steel and aluminum measures.

Content-based assessment creates its own data obligations. Importers must declare the value of the steel or aluminum content and must be able to provide documentation sufficient to support the claimed base-metal content and value if CBP requests it. Melt-and-pour and smelt-and-cast information is reported alongside that content data, and errors in either can change the duty owed.

The Narrow Exclusion for U.S.-Produced Metal

The proclamations include a narrow exclusion for derivative products processed in another country from metal produced in the United States: derivative steel products made from steel that was melted and poured in the United States, and derivative aluminum products made from aluminum that was smelted and cast in the United States. The exclusion recognizes that U.S.-produced metal exported for foreign processing and returned as a derivative product should not be treated as foreign metal.

Claiming the exclusion depends entirely on the data: the importer must be able to show where the metal was melted and poured or smelted and cast. A manufacturer that sends U.S. steel or aluminum abroad for processing should build a documentation trail — mill certifications, purchase records, shipment records, and supplier declarations — that ties the returning product to the U.S.-produced metal.

Where the Data Comes From

Importers rarely produce the metal themselves, so melt-and-pour and smelt-and-cast information must come from the supply chain. Typical sources include:

Mill certifications and test reports issued by the producing mill, which identify the producing facility and heat or lot information.
Supplier declarations from fabricators and distributors identifying the mill and country where the metal was produced.
Purchase and traceability records linking specific heats or lots of metal to the finished goods shipped to the United States.
Contract terms requiring suppliers to provide origin data for every shipment and to notify the importer of changes in metal sourcing.

Multi-tier supply chains make this harder. A fabricator may buy steel from a service center that sourced it from several mills, and an assembler of aluminum-containing goods may not know which smelter produced the metal in a purchased component. Building contractual obligations and verification processes up the chain is the only reliable way to obtain accurate data.

The Cost of “Unknown”: A Simple Illustration

Consider a hypothetical derivative aluminum product whose declared aluminum content is valued at $100,000 on an entry. If the importer has documentation identifying the smelt and cast countries, the Section 232 duty on that content is calculated at the rate applicable to those countries. If the importer cannot identify the smelt or cast country and must report “unknown,” the content is assessed the 200 percent rate applicable to Russian aluminum — $200,000 of Section 232 duty on $100,000 of aluminum content, in addition to any other duties owed on the entry. The arithmetic is simple, and it explains why supplier data on smelt and cast has become a commercial priority rather than a paperwork exercise.

Consistency With Commerce Import Licensing

For covered steel and aluminum mill products, Commerce’s import monitoring programs require import licenses, and the license applications collect production-country information. That information should be consistent with the melt-and-pour or smelt-and-cast data declared on the entry summary. Inconsistencies between the two invite questions from CBP and Commerce and can undermine the credibility of the importer’s data generally. A single source of truth for production-country data, shared with the person filing license applications and the customs broker, avoids that problem.

Compliance Risks

Melt-and-pour and smelt-and-cast declarations are entry data subject to the importer’s duty of reasonable care under 19 U.S.C. § 1484. Inaccurate declarations — whether a wrong country, an unsupported claim of U.S.-produced metal, or an overstated or understated metal-content value — can result in underpaid duties and exposure to penalties under 19 U.S.C. § 1592. Several risk patterns recur:

Reporting the country of fabrication instead of the country of melt and pour.
Reporting a smelt or cast country without documentation, rather than reporting “unknown” where required.
Claiming the U.S.-metal exclusion without traceability records linking the product to U.S.-produced metal.
Declaring metal content values that cannot be supported by cost or engineering data.
Failing to update data when a supplier changes mills.

Because duty rates on steel and aluminum and their derivatives are significant, the dollar consequences of these errors can be large, and CBP has focused attention on Section 232 data accuracy.

Questions to Ask Your Suppliers

A supplier questionnaire focused on Section 232 data can surface gaps before they become duty problems. Useful questions include:

Which mill or smelter produced the steel or aluminum in each product you sell us, and in which country?
For aluminum, in which country was the metal cast, and was it recast or remelted after smelting?
Can you provide mill certifications or equivalent records tying each shipment to the producing facility?
Do you source metal from more than one producer for the same product, and how do you track which producer’s metal is in each lot?
For products containing steel or aluminum, what is the weight and value of the metal content, and how is that value calculated?
Will you notify us in advance if you change metal sources?

Suppliers that cannot answer these questions present a real risk, particularly for aluminum derivatives, where missing smelt or cast information leads directly to the “unknown” declaration and the 200 percent rate.

Building a Compliance Program

Identify covered products. Map your imports against the steel and aluminum HTS classifications and the derivative product lists covered by the Section 232 measures.
Collect data before shipment. Require melt-and-pour or smelt-and-cast information, and metal-content data for derivatives, as a condition of each purchase order.
Verify, don’t just collect. Cross-check supplier declarations against mill certifications and periodically audit suppliers.
Align with your broker. Confirm your customs broker receives the data in time to transmit the 54-record declarations correctly.
Document exclusion claims. Maintain traceability files for any claim of U.S.-melted or U.S.-smelted metal.
Correct errors promptly. Where errors are found, evaluate post-summary corrections for unliquidated entries and, where appropriate, a prior disclosure to mitigate penalty exposure.

Correcting Past Entries

When an internal review finds that past entries reported the wrong country, claimed an exclusion without support, or misstated metal content, the available remedies depend on each entry’s status. Unliquidated entries can often be corrected through a post-summary correction within CBP’s time limits. After liquidation, an importer that believes too much duty was assessed may protest within 180 days under 19 U.S.C. § 1514. Where errors resulted in underpaid duties, a prior disclosure under 19 U.S.C. § 1592(c)(4), made before CBP begins a formal investigation of the violation, can substantially reduce penalty exposure. The choice among these tools — and the order in which to use them — should be made deliberately, because an incomplete correction can create more risk than it resolves.

Why This Matters for California Importers

California’s manufacturers, distributors, and retailers import large volumes of steel and aluminum products and derivative goods — from building materials and auto parts to consumer goods and machinery. Many of these products reach the United States through multi-country supply chains where the metal was produced in one country and processed in another. For these importers, melt-and-pour and smelt-and-cast reporting is no longer a technical data field. It can decide whether an exclusion applies, how much duty is owed on a derivative product, and whether missing information triggers a 200 percent duty.

Frequently Asked Questions

What is the country of melt and pour?

The original location where raw steel was first produced in a steel-making furnace in a liquid state and poured into its first solid shape, such as a slab, billet, ingot, or finished mill product.

When did the melt-and-pour declaration requirement change?

A requirement to report the steel country of melt and pour through the Importer’s Additional Declaration Type Code 08 on the entry summary’s 54 record became effective November 21, 2024.

What are the countries of smelt and cast?

For aluminum, the country where primary aluminum was smelted and the country where it was cast. Both are reported on the entry summary for covered aluminum imports.

What happens if I report “unknown” for aluminum?

Effective June 28, 2025, for derivative aluminum subject to Section 232, an importer that does not know the smelt or cast country reports “unknown,” must report HTS 9903.85.67 or 9903.85.68 as applicable, and is assessed the 200 percent Section 232 duty that applies to aluminum from Russia.

How are Section 232 duties applied to derivative products?

Under CBP guidance, for derivative articles not wholly made of steel or aluminum, the duty is assessed on the value of the steel or aluminum content, provided the entry is reported correctly and the content value can be documented.

Is my customs broker responsible for melt-and-pour and smelt-and-cast data?

The broker transmits the data, but the importer of record bears the duty of reasonable care for the accuracy of its declarations. The importer must obtain the information from its supply chain, provide it to the broker, and be able to support it if CBP asks.

Are Section 232 duties refunded along with IEEPA tariffs?

No. Section 232 duties are imposed under a different statute and were not affected by the Supreme Court’s February 2026 IEEPA decision. Only the IEEPA portion of an entry’s duties is potentially refundable on that basis.

Is there an exclusion for U.S.-produced metal?

Yes, a narrow one: derivative products processed abroad from steel melted and poured in the United States, or from aluminum smelted and cast in the United States, can qualify, provided the importer can document it.

Related Customs & Trade Guides

Talk to a Customs Attorney About Section 232 Data

Where your metal was made can change what you owe. Trembach Law Firm helps California importers build Section 232 data programs and correct or defend steel and aluminum entries, working alongside your customs broker and suppliers. Call (213) 645-2246.

Contact Trembach Law Firm at (818) 514-7680 for a confidential consultation.

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