Due to the recent expansion of Section 232 to include an additional 407 tariff numbers—requiring a 50% duty on the steel or aluminum content—many importers are impacted.

Reporting melt and pour or smelt and cast origin at the part level has become a significant challenge, particularly for suppliers who source materials from multiple countries. We have raised this issue with U.S. Customs and are currently awaiting formal guidance.

In the meantime, cargo must continue to move.  Therefore, we strongly recommend that every effort is made to provide the country of origin you and your supplier believe to be the most likely source. If there is any possibility that steel or aluminum content originates from Russia, Belarus, or North Korea, we urge to err on the side of caution and declare those countries. That said, we understand some may have internal policies that already prohibit sourcing from these nations.

Please keep in mind that the standard of reasonable care requires importers to make diligent and accurate declarations to the best of their ability.  Perfection under these circumstances is difficult, after a part has fully lost its ‘origin’ as the steel or aluminum it once was.  While definitive direction from Customs is still pending, we are providing this guidance based on our professional judgment as Licensed Customs Brokers.

Important: Our team cannot make origin determinations. They will be contacting clients directly to request the necessary information.

We strongly encourage you to:

• Retain a copy of this communication in your records to demonstrate reasonable care.
• Consult outside legal counsel, if available, for additional compliance advice.

We will continue to monitor developments and share updates as soon as new guidance becomes available.

September 4, 2025