By Kerry Wang, Senior Associate Attorney, Braumiller Law Group
We are operating in one of the most volatile trade environments in recent memory. Tariff policy is shifting faster than most compliance programs can absorb. In that context, CBP’s March 15 guidance on Section 232 content value is not just a technical update. It brings meaningful clarity and importers who move quickly may find real money on the table.
On March 15, CBP’s Base Metals Center of Excellence and Expertise issued revised informal guidance on determining metal content for Section 232 purposes. This is not a binding ruling, but it reflects CBP’s current enforcement position and is the framework importers and counsel are working with today.
For articles that are not wholly made of the subject metal, Section 232 duties apply only to the value of the steel, aluminum, or copper content. Non-subject components such as glass, plastic, rubber, and similar parts can be separated out. What cannot be subtracted are costs such as labor, overhead, fabrication, packaging, and coating. Where those costs are attributable to both subject and non-subject content, apportionment by value ratio is acceptable.
The guidance reminded importers of a critical limitation: while all steel contains iron, the chemistry of a steel article cannot be disaggregated to carve out a non-Section 232 iron component. You cannot back into an exemption by pointing to iron in the composition of steel. In this article, I want to focus on another consequential update in this guidance: iron.
The Iron Timeline
From the start of the tariffs in March 2018 through March 11, 2025, Section 232 coverage was based solely on HTSUS classification. If your article was on the list, you paid as there is no distinction. Iron or not.
That changed in two phases:
- March 12 – June 3, 2025: Iron content in derivative articles classified outside Chapter 73 was no longer subject to the Section 232 duty. Two exceptions applied: subheadings 8708.10.30 (bumper stampings of steel) and 8708.29.21 (body stampings for agricultural tractors) remained subject to duty.
- June 4, 2025 – present: Iron articles and iron parts classified in Chapter 73 — and iron content in derivative articles classified elsewhere — generally do not pay Section 232. Iron products in Chapter 72, and the same two Chapter 87 subheadings noted above, remain subject to duty.
The Refund Opportunity
Here is what that timeline means in practice: any importer who paid Section 232 duties on iron content without accounting for these phase changes may have overpaid going back to March 12, 2025. Those entries may be eligible for a refund.
The exceptions are genuinely complex and classification is critical. Value calculations require careful analysis of how costs like labor and packaging are allocated across subject and non-subject components. Documentation also matters as CBP has not prescribed a specific format, therefore a consistent, defensible methodology is essential to any refund claim.
If you believe your imports may have been assessed Section 232 duties on iron content, now is the time to evaluate your entries. Our firm has been working with importers to identify overpayments and pursue refund opportunities under this guidance. We can help you do the same.