For Steel, Aluminum, and Derivatives.
We map your Section 232 exposure and pursue relief where the law allows it — HTS 9903 duty analysis, BIS exclusion requests, and country quota and TRQ planning from advisors who file the entries these duties land on.
Trusted by leading importers & manufacturers
Section 232 is the national-security tariff authority. Under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862), the President can impose duties on imports the Commerce Department finds threaten national security, which is how the 25% duty on steel and the aluminum duty were imposed by proclamation.
This is a different legal track from the China tariffs. Section 301 duties come from the U.S. Trade Representative under trade-act authority, and if that is your exposure our Section 301 tariff exclusion desk is the right starting point. Section 232 relief instead runs through the Commerce Department's Bureau of Industry and Security, which administers the product exclusion process, so the mechanism, the evidence, and the portal are entirely separate.
The work starts with classification. Whether an article is even in scope turns on its HTS code and whether it appears on the derivative-product annexes, which is why we tie 232 analysis to disciplined Harmonized Tariff Schedule work and to country-of-origin determination, since the duty, any quota, and any exemption all depend on where the metal was made.
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HTS chapter we work in
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Exclusions Portal filings
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Response time
Six advisory services our trade experts use to size, defend, and reduce your Section 232 duty burden.
We pull your steel, aluminum, and derivative entries and identify every line touched by a 9903 duty.
We confirm in-scope status, screen General Approved Exclusions, and test each line for an exclusion path.
We choose between an exclusion request, quota and TRQ timing, or origin change and quantify each option.
We file exclusion requests in the 232 portal and our brokers apply granted exclusions at entry.
We track annex and GAE changes, recover overpaid duty, and re-check exposure as proclamations shift.
Section 232 duties are not a fixed line item. Whether they apply, at what rate, and whether an exclusion is available all turn on classification, origin, and a Commerce process most importers never fully work.
CargoTrans turns that into a concrete plan: correct 9903 treatment, exclusion requests where they hold up, and quota timing that protects your margin.
The real-time Control Tower gives your team a live view of which entries carry a 9903 duty, which exclusions are applied, and where quota or TRQ limits are filling, so a scope change or an expiring exclusion surfaces as an alert rather than a surprise at liquidation.
Behind it, Captain Trade Advisory ties each 232 duty line to the classification and origin decision that drives it, and connects to our tariff and customs duty consulting so the relief strategy and the filed entry stay in sync.
A BIS exclusion request is only as strong as its technical detail and its domestic-availability case. We build each request with the product specifications, volumes, and delivery evidence that answer the objections a domestic producer is likely to file, because a granted exclusion is worth far more than a fast one that gets denied.
Because the same team advises on the request and files your entries, a granted exclusion number is applied correctly at entry and overpaid duty from before the grant is recovered through post-summary correction or protest, so the relief on paper becomes relief in your account. Where your exposure is really Section 301 rather than 232, we route it to the Section 301 exclusion process instead.
Section 232 is a national-security tariff authority under Section 232 of the Trade Expansion Act of 1962, codified at 19 U.S.C. 1862. It lets the Commerce Department investigate whether imports threaten national security and, if the President agrees, impose duties or quotas by proclamation. That is the legal basis for the tariffs on steel and aluminum and their derivative products. Section 301 is entirely separate: it comes from the U.S. Trade Representative under the Trade Act of 1974 and is the basis for the China tariffs. The two use different agencies, different investigations, and different relief processes. Section 232 exclusions go through the Commerce Department's Bureau of Industry and Security, while Section 301 exclusions go through USTR. Treating them as one generic tariff is the most common and expensive mistake importers make.
It comes down to classification. Section 232 duties attach through Chapter 99 of the Harmonized Tariff Schedule, in the 9903.80 subheadings for steel and the 9903.85 subheadings for aluminum, and a product is covered only if its underlying HTS code appears on the proclamation lists or the derivative-product annexes. Raw steel and aluminum have been covered from the start, but the scope has since expanded to derivative articles like fasteners, tubing, stampings, and other downstream goods. We review your actual HTS classifications against the current 9903 subheadings and the derivative annexes and issue a determination for each line, because assuming a finished good is out of scope when a derivative annex actually captures it leads to underpaid duty and penalty exposure later.
A Section 232 exclusion request asks the Commerce Department to exempt a specific product from the 232 duty, generally on the grounds that the article is not produced in the United States in sufficient quantity or quality, or that a national-security consideration warrants it. Requests are filed through the Commerce 232 Exclusions Portal administered by the Bureau of Industry and Security. Once filed, domestic producers can submit objections asserting they can supply the product, and you may respond with rebuttals and surrebuttals. BIS then decides. A request must be product-specific, with real technical specifications and volumes, because a vague filing invites an objection that a precise one would defeat. If granted, the exclusion carries a number and an approved quantity that must be applied at the time of entry to get the duty relief.
A General Approved Exclusion, or GAE, is a standing exclusion that Commerce has already approved for certain HTS codes, so any importer of a qualifying article can use it without filing an individual request. GAEs exist because some products have consistently drawn no domestic objection, and issuing a blanket exclusion saves both the importers and BIS from processing repetitive individual filings. Before we prepare a full exclusion request, we screen your articles against the current GAE list, because if a GAE already covers your product you can claim the relief directly and skip the request entirely. GAEs are added and removed over time, so we monitor the list and confirm the certification and recordkeeping requirements are met, since claiming a GAE still requires that your entry properly qualify.
Section 232 relief and burden vary by country of origin. Most countries face the ad valorem duty, meaning a percentage added to the metal's value. Some countries negotiated an absolute quota instead, a hard cap on how much can enter in a period, with no imports allowed once the cap fills. Others operate under a tariff-rate quota, or TRQ, where a set volume enters at a lower or zero rate and volume beyond the quota is charged the higher duty. Which regime applies turns entirely on where the steel or aluminum was made, which is why country-of-origin determination is central to any 232 plan. For quota and TRQ countries, entry timing matters, because filing after a quota period fills can mean your goods are held or charged the over-quota rate. We plan sourcing and entry timing around those limits.
Because the duty, any exemption, and any quota all depend on where the metal was actually made, not where it shipped from. A steel article melted and poured in one country and lightly processed in another does not necessarily take the origin of the last country it passed through. Section 232 has specific rules and reporting for the country of melt and pour for steel and the country of smelt and cast for aluminum, and getting that wrong can mean you apply the wrong duty, claim a quota exemption you are not entitled to, or miss one you are. We handle this through disciplined country-of-origin analysis tied to your classification, so the origin you declare on the entry matches the origin the 232 regime actually keys off, and your duty, quota, or exemption treatment holds up.
Sometimes, and the path depends on why the duty should not have applied. If you obtain a product exclusion, the exclusion generally allows relief on entries within its terms, and where entries are still within the correction or protest window we recover the overpaid duty through a post-summary correction or a protest under the customs rules. If an entry was simply misclassified into a 9903 subheading that never should have applied, that is a classification correction. Recovery is time-sensitive, because entries liquidate and the protest window closes, after which the overpayment usually becomes unrecoverable. Because our brokers filed or can review the entries, we identify which entries are still open, apply the granted exclusion number, and file the corrections before the deadlines pass rather than discovering the money is gone.
Yes. Section 232 duties are additional to the normal Chapter 1-97 duty rate for the product, and they can also sit alongside other special tariffs depending on the goods and origin, including Section 301 duties where both regimes reach the same article. That stacking is exactly why modeling matters: the headline metal duty is only part of the true landed cost, and a line that carries a base rate, a 232 duty, and another special duty can cost far more than a quick look suggests. We build a line-level model that shows every layer applied to each article, so purchasing and pricing decisions are made against the real all-in duty rather than a single rate, and so you can see where an exclusion or an origin change would actually move the number.
General customs consulting builds the reasonable care and compliance program behind all of your entries, across classification, valuation, origin, and recordkeeping. Section 232 consulting is a focused specialty inside that: it is specifically about the national-security steel and aluminum duties, the 9903 chapter they run through, the Commerce exclusion process, and the quota and TRQ regimes by country. An importer with no metal exposure may never need it, while a metal-intensive importer may need it as their single largest duty question. We treat it as a distinct engagement because the mechanism, the agency, and the evidence are specialized, but it connects directly to your broader compliance program so a 232 decision is documented with the same reasonable care as every other entry position you take.
A sample of your recent entry summaries and your product HTS classifications is enough to start. From the entries we can see which lines already carry a 9903 duty and at what rate, and from the classifications and product specifications we can test whether any additional lines fall under the steel or aluminum derivative annexes that you may not have flagged. We also need the country of origin, and for metal the country of melt and pour or smelt and cast, because that drives whether you face the duty, a quota, a TRQ, or an exemption. With that, we can size your total 232 exposure, screen for General Approved Exclusions, and tell you which lines have a realistic exclusion path, all in the free initial review.
It starts with a free 30-minute exposure review. Send a sample of recent entry summaries and your product classifications, and we will identify every line touched by a 9903 steel or aluminum duty, screen for General Approved Exclusions, and flag the lines with a realistic exclusion or origin-change path, with no obligation. From there we scope the work to your situation: preparing and filing exclusion requests through the Commerce portal, planning around quota and TRQ limits, modeling landed cost, and recovering overpaid duty on entries still within the correction window. Because our licensed brokers file entries daily, we move directly from strategy to applying granted exclusions at entry, rather than handing a paper approval to another firm to implement.
