On December 3, 2025, U.S. Customs and Border Protection’s (CBP) base metals Center of Excellence and Expertise (CEE) issued new guidance on valuing steel, aluminum and copper content for purposes of calculating Section 232 tariffs.

CBP’s guidance clarifies that tariffs on steel and aluminum articles that contain only steel or aluminum content are assessed on the full entered value of the article. This includes manufacturing and labor costs, which cannot be subtracted from the entered value. The guidance also applies to articles containing copper or brass that are subject to separate Section 232 tariffs. 

For derivative articles that are not wholly made of steel or aluminum, the Section 232 tariffs are assessed on the steel or aluminum content of the finished article. The steel or aluminum content is based on “the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content”. Thus, subtracting fabrication, machining, labor, costs to arrive at the price of the raw steel or aluminum is not permissible.

This also includes costs of surface treatments like galvanizing and anodyzing as well as the costs of painting, lacquering or coating, which must be retained. For copper, the value of the alloying elements cannot be deducted. However, packing costs can be apportioned across the metal and non-metal content.

Where value of the steel/aluminum content cannot be determined, CBP advises importers to report the duty based on the total entered value, on one entry summary line.

CBP acknowledges that reporting the steel/aluminum and non-steel/aluminum content requires seeking additional information from the manufacturer or seller on the cost of the metal or non-metal content in the article sold to the importer. In any event, an importer must be able to provide documentation sufficient to support the importer’s claimed steel/aluminum content value.  Furthermore, CBP has not clarified whether the above guidance applies to purchases of steel, aluminum, or copper from related upstream suppliers of the metal.

If you have any questions on valuation of articles for purposes of section 232 tariffs or how this might impact your business, please contact the Husch Blackwell Trade Team.