By: Brian Walczyk, Compliance Manager, TradeInsights, LCB, CCS

The Center for Excellence and Expertise (CEE) of Base Metals has been circulating informal guidance to Trade regarding the calculation of steel, aluminum, and copper content value for Sec 232 purposes for several months.

The guidance was updated, dated March 15, and continues to maintain much of the same guidance issued from Jan 15.

A new section was added to cover Sec 232 articles of iron. The iron content is said to be determined in the same manner as that of steel and aluminum. Of emphasis was there is no breaking down of the chemistry of a steel article to arrive at a separate, non-Sec 232, iron content.

The guidance does also provide a helpful timeline on when the Sec 232 assessment made a distinction between steel and iron (June 4, 2025).

This informal guidance is currently a central pillar in the Express Fasteners v. The United States case before the Court of International Trade, but is how US CBP has been taking action on Sec 232 steel, aluminum, iron, and copper entries.

Importers should continue to document their valuation of derivative articles carefully, and should consider the information in the informal guidance when preparing to import such articles.

We will continue to monitor this situation and issue updates as needed.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.