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Customs Issues Guidance on How to Report Revised Steel, Aluminum, and Copper at Time of Entry

By Nithya Nagarajan & Emily Mikes on April 4, 2026
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U.S. Customs and Border Protection (“CBP”) issued guidance on how importers need to report and classify goods subject to the revised steel, aluminum, and copper tariffs announced by the Trump Administration on April 2, 2026. We encourage importers to review the list of HTS number affected by the metal tariffs to ensure compliance with the below reporting requirements.

The following HTS numbers must be used by importers at the time of entry:

  • 9903.82.02: Except as provided for in headings 9903.82.14, 9903.85.67 and 9903.85.68, applies to articles of aluminum, of steel, or of copper and derivative aluminum or steel articles, as provided for in subdivision (c)(i)-(v) of U.S. note 16 to this subchapter.
    • 50% additional ad valorem rate of duty
  • 9903.82.03: Except for articles classifiable in chapters 72, 73, 74, or 76, articles where the weight of the applicable metal is less than 15 percent of the weight of the imported article, as provided for in subdivision (c) of U.S. note 16 to this subchapter.
    • 0% additional ad valorem rate of duty

When reporting HTSUS 9903.82.03, report the aggregate weight of the applicable metal(s) in kg as a second quantity on the entry summary line.

  • 9903.82.04: Applies to articles of aluminum or of steel and derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(i)-(iv) and (d) of U.S. note 16 to this subchapter.
    • 25% additional ad valorem rate of duty
  • 9903.82.05: Applies to derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(vi)-(vii) and (d) of U.S. note 16 to this subchapter.
    • 15% additional ad valorem rate of duty
  • Headings 9903.82.06, 9903.82.07, and 9903.82.08 will apply to certain articles of copper and derivative aluminum and steel articles provided for in subdivision (c) of this note.
    • For derivative articles provided for in subdivisions (c)(ii), (vi), and (ix), at least 95 percent of the aluminum content of the article must be composed of aluminum that was smelted and cast in the United States.
    • For derivative articles provided for in subdivisions (c)(iv), (vii), and (x), at least 95 percent of the steel content of the article must be composed of steel that was melted and poured in the United States.
    • For articles provided for in subdivision (c)(viii), at least 95 percent of the copper content of the article must be composed of copper that was smelt and cast in the United States (see below for reporting requirements).
    • These requirements are cumulative such that a derivative article in more than one subdivision must satisfy each requirement.
  • 9903.82.06: Except as provided for in headings 9903.82.15 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(ii), (iv), (vi) – (viii), and (e) of U.S. note 16 to this subchapter. 
    • 10% additional ad valorem rate of duty
  • 9903.82.07: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.

For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 10%.

  • 9903.82.08: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.

For articles for which the applicable column 1 duty rate is 10 percent or higher, no additional duty is due.

  • 9903.82.09: Except as provided for in headings 9903.82.16 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(vi)-(viii) of U.S. note 16 to this subchapter.
    • 25% additional ad valorem rate of duty
  • 9903.82.10: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter (not 95 percent melted and poured or smelted and cast in the U.S.)

For articles for which the applicable column 1 duty rate is less than 15 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 15%.

  • 9903.82.11: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter (not 95 percent melted and poured or smelt and cast in the U.S.)

For articles for which the applicable column 1 duty rate is 15 percent or higher, no additional duty is due.

  • 9903.82.12: Except as provided for in headings 9903.82.17 and 9903.85.68 applies to derivative aluminum and steel articles, the product of any country identified in general note 3(b) (countries subject to the column 2 duty rates in the HTSUS), as provided for in subdivision (c)(ix)-(x) of U.S. note 16 to this subchapter.
    • 25% additional ad valorem rate of duty
  • 9903.82.13: Applies to articles that otherwise meet the criteria of subdivisions (c)(vi)-(viii) that are motorcycle parts classifiable in chapter 84, 85, or 87 for use in the manufacturing of motorcycles in the United States.
    • 0% additional ad valorem rate of duty
  • 9903.82.14: Applies to articles of steel or of copper and derivative steel that are the product of the Russian Federation as provided for in subdivisions (c)(iii)–(v) of U.S. note 16 to this subchapter.
    • 50% additional ad valorem rate of duty
  • 9903.82.15: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(iv), (vii), (viii) and (e) of U.S. note 16 to this subchapter.
    • 10% additional ad valorem rate of duty
  • 9903.82.16: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(vii)–(viii) of U.S. note 16 to this subchapter.
    • 25% additional ad valorem rate of duty
  • 9903.82.17: Applies to derivative steel articles that are the product of the Russian Federation, as provided for in subdivision (c)(x) of U.S. note 16 to this subchapter.
    • 25% additional ad valorem rate of duty
Link to Russia Aluminum Duties Russia Aluminum Duties

All imports of aluminum articles and aluminum derivative articles covered by this Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of these aluminum articles is smelt in Russia, or these aluminum articles are cast in Russia, shall continue to be subject to the 200 percent ad valorem rate of duty under HTSUS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products.

Russia aluminum and aluminum derivative products subject to HTSUS headings 9903.85.67 and 9903.85.68 may not be reported under HTSUS 9903.82.03.

Link to Reporting of Countries of Melt and Pour and Smelt and Cast Reporting of Countries of Melt and Pour and Smelt and Cast

Continue to report the countries of melt and pour for all subject steel and steel derivative products and the countries of smelt and cast for all subject aluminum and aluminum derivative products. See, e.g., Cargo System Messaging Service messages 64348411, 64348288, and 65340246 for reporting instructions.

CBP will issue a CSMS to announce when the reporting of the countries of copper smelt and cast will be required and the corresponding functionality is available in ACE for imports of copper products under the following HTSUS classifications:8544.42.10; 8544.42.20; 8544.42.90; and 8544.49.10.

There is no guidance or clarification as to whether Section 232 tariffs on steel, aluminum, and copper products will be stacked with Section 301 and Section 122 tariffs.

The Husch Blackwell International Trade and Supply Chain team will continue to monitor and provide updates as they become available.

Tags: Trump Tariffs
Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

Read more about Nithya NagarajanEmail
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Photo of Emily Mikes Emily Mikes

Emily focuses on export controls, economic sanctions and related government investigations. She advises clients in a wide array of industries on the specifics of trade regulations, analyzing the effects of rules and restrictions on businesses as they import and export goods and materials.

Read more about Emily MikesEmail
  • Posted in:
    Tax
  • Blog:
    International Trade Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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