The Complete BIS Section 232 Playbook for SMB Importers

TL;DR

Section 232 of the Trade Expansion Act of 1962 lets Commerce/BIS investigate whether imports of a specific commodity threaten US national security — the President can then impose tariffs, quotas, or a combination by proclamation.

For SMB importers of steel, aluminum, and (2025-2026) derivative metals products, Section 232 exposure has widened materially — the "derivative" rulemakings pull in fabricated goods that were previously outside 232's scope.

The exclusion process (BIS Portal / Form 3169) is real, but each individual exclusion is product-specific, importer-specific, and time-limited — treat it as a moving compliance workload, not a one-time filing.

The BIS public-comment window (regulations.gov docket) on each 232 rulemaking is the one lever SMB importers actually have — a well-drafted comment with documented economic-harm evidence is the strongest tool short of litigation.

Stack of duties applies: Section 232 + Section 301 + MFN + antidumping/countervailing duties can all layer on the same entry — the answer is a full duty-stack model per SKU, not a per-program calculation.

Key stat: BIS Section 232 exclusion decisions are published in the Federal Register with named importers and product descriptions — competitors' granted/denied exclusions are public and searchable, which is the single most useful signal for whether your own filing has a realistic path.

A national-security tariff law from 1962 is quietly rewriting your landed cost — and the process that decides whether your product is next runs on a public clock almost nobody watches.

The three-month call from your broker

Here's how it usually goes. You import a product — maybe it's a bracket, a fastener, an appliance part, a piece of outdoor furniture hardware. Steel or aluminum makes up something like 30% of its value. You've never thought about it as a "steel product." You think about it as a part number.

Then a domestic steel or aluminum producer — a competitor to your supplier, not to you — files a petition with the Bureau of Industry and Security asking to add your HTS code to the Section 232 derivatives list. This isn't a rumor or a trade-press leak. It's a formal submission, posted publicly, sitting inside a defined comment window that anyone can read.

Nobody tells you directly. Why would they? You're not a party to the petition. You're just the importer whose landed cost is about to move.

Three months later your broker calls. Your HTS code got added. You now owe a 50% duty on the steel or aluminum content value of every entry, going back to whenever the new Chapter 99 code took effect. Your margin on that SKU is gone, maybe underwater, and you're finding out about a decision that was public for weeks before it became binding.

This is the part almost no SMB importer understands about Section 232 in 2026: it is not a static tariff you check once and file away. It is a recurring, dated administrative process — three windows a year, roughly two weeks each, decisions on a clock — and your exposure changes every time that window opens, whether you're watching or not.

This playbook is the watching part.

1. Section 232 in plain English

Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. § 1862) lets the President restrict imports that the Secretary of Commerce determines threaten to impair national security. It's not a trade-remedy statute in the antidumping/countervailing-duty sense — it doesn't require proof of unfair pricing. It requires a national-security finding, an investigation run by the Commerce Department, and a presidential decision on remedy.

For decades this was a rarely-used tool. That changed in 2018. Commerce completed Section 232 investigations into steel and aluminum imports, and the President acted on them through two proclamations: Proclamation 9704 (aluminum) and Proclamation 9705 (steel), both issued in March 2018. Proclamation 9705 set a 25% tariff on covered steel articles. Proclamation 9704 set a 10% tariff on covered aluminum articles. Country exemptions and quota deals came and went over the following years — Canada, Mexico, the EU, the UK, South Korea, and others cycled through different arrangements at different points.

The rates did not stay put. Aluminum's rate was later raised from 10% toward parity with steel, and starting in 2025 both metals saw a further, larger escalation — reporting and BIS/Commerce actions through 2025 pushed the baseline rates for many countries up again, with steel and aluminum both cited at substantially higher levels than the original 2018 rates for most trading partners. Treat any specific percentage you read — including in this article — as a snapshot, not a fact you bank on. The rate that applies to your entry on the day it clears is the rate in the current proclamation and its Federal Register implementation, not the rate you remember from a headline. Before you quote a number to your CFO, pull it fresh from the Federal Register or BIS's Section 232 program page at bis.doc.gov.

What matters more than any single rate, for the purposes of this playbook, is the mechanism: Commerce/BIS administers the program, proclamations set and change rates and coverage, and — critically for SMB importers — the definition of what counts as a "covered" article has expanded far past raw steel and aluminum mill products. That expansion is the part most importers miss, and it's the subject of the next section.

2. Derivative articles — how the net got wider

The original 2018 proclamations covered steel and aluminum in mill forms — flat products, bars, pipes, extrusions, and the like. If you imported finished goods that merely contained steel or aluminum, you were outside the tariff. That distinction didn't last.

In January 2020, the administration expanded Section 232 to cover certain "derivative" articles — products one step downstream of raw metal, like certain nails, stranded wire, and specific steel and aluminum stampings used in vehicles. This was the first signal that the government was willing to reach past mill products into fabricated goods, using the theory that surging derivative imports were undermining the original tariffs' purpose by giving importers an end-run.

That 2020 expansion was narrow compared to what came next. In February 2025, BIS and the White House executed a much larger expansion of the derivative product lists — pulling in a long roster of downstream, fabricated products across categories including appliances, furniture components, structural building products, fasteners, and auto parts. This is the expansion that actually matters to most SMB importers reading this, because it's the one that turned "steel tariff" from a raw-materials issue into a finished-goods issue.

The mechanical detail that trips people up: for many derivative products, the duty is not assessed on the full entered value of the article. It's assessed on the steel or aluminum content value — the portion of the product's value attributable to the steel or aluminum in it. A steel garden shed that's 60% steel by value pays the 232 rate on that 60%, not on the whole invoice price. That sounds like relief. In practice it creates a compliance burden almost as large as the duty itself, because now you need a defensible content-value calculation for every affected entry — which is exactly what Section 6 below walks through.

The list of covered derivative HTS codes is not fixed. It has been added to multiple times since 2018, and — this is the whole point of this article — it now has a standing, recurring process for adding more. Which brings us to the mechanism you actually need to understand cold.

3. The BIS inclusions process — the recurring cycle

This is the section to bookmark.

In 2025, BIS established an interim final rule creating a formal inclusions process for the steel and aluminum derivative lists — a standing administrative pathway for adding new HTS codes to Section 232 coverage without a new full Section 232 investigation each time. Instead of the President having to launch a fresh national-security investigation every time someone wants a product added, domestic steel and aluminum producers (or industry groups) can petition BIS directly to add specific derivative products to the existing proclamations.

The mechanics, as designed:

Submission windows. BIS opens petition windows roughly three times per year, each lasting approximately two weeks. During a window, any eligible petitioner — typically a domestic producer or industry association — can submit a request to add a specific HTS code (or group of codes) to the derivative steel or aluminum lists.

A defined review clock. Once a window closes, BIS reviews submitted petitions against a set timeline — historically discussed in the roughly 60-day range from window close to determination, though you should treat the exact day-count as something to verify against the current version of the rule rather than something to build a legal argument on.

A comment period. Interested parties — including importers who would be affected — generally get an opportunity to submit comments on pending petitions before BIS decides. This is your one formal shot to argue against inclusion (see Section 8).

Effective dates. If BIS grants inclusion, the new HTS codes get added to the Chapter 99 coverage, generally with an effective date tied to Federal Register publication — sometimes with limited or no retroactivity, sometimes applying to goods entered on or after a stated date. The exact retroactivity treatment has varied by rule, so this is a detail to confirm for each specific inclusion, not assume.

Why this matters more than the base tariff rate: the base rate is (relatively) stable and well-publicized. The product list is not. Three times a year, a new batch of HTS codes can be added by a process that most SMB importers have never heard of, driven by petitions from companies you've never interacted with, for products that may look nothing like "steel" or "aluminum" on your packing list. Your furniture-hardware supplier's product wasn't covered in January. It might be covered by September. Nobody calls to warn you. The petition, the comment window, and the determination are all public — but "public" and "on your radar" are different things unless you build a habit around it (Section 10 covers exactly how).

If you take one structural fact from this entire article, take this one: Section 232 exposure for a derivative-goods importer is not a status, it's a moving target with three scheduled opportunities per year to move.

4. How to determine if your product is covered today

Before you can manage the moving target, you need to know where you stand right now.

Start with HTS Chapter 99. Section 232 duties are implemented through special Chapter 99 provisions layered on top of your product's normal HTS classification (Chapter 1–97). Steel and aluminum 232 coverage has generally been implemented through headings in the 9903.80 through 9903.85 range, with different sub-ranges used for steel versus aluminum, for derivative versus non-derivative articles, and for country-specific treatment. The exact subheading assigned to your product changes as the lists get amended — don't memorize a number from a 2023 article (including, eventually, this one) and assume it still applies. Pull the current Chapter 99 text directly from hts.usitc.gov or your broker's classification software before you rely on it.

Read the annexes, not just the headline. BIS and CBP publish the derivative product annexes as long tables of specific 10-digit HTS numbers, sometimes with descriptive carve-outs (e.g., "except when imported as parts of X"). Your product may share a 6-digit heading with a covered item but sit on an uncovered 10-digit line, or vice versa. This is not a skim-the-summary exercise — someone needs to check your actual entered HTS numbers against the actual annex line items.

Ask your broker three specific questions, not one vague one. "Am I affected by steel tariffs?" gets you a shrug. Ask instead:

"For HTS code [X], is there an active Chapter 99 steel/aluminum derivative overlay, and what's the current rate?"

"Does my import require a steel/aluminum content value reported separately on the entry, and if so, what documentation are you requesting from me for that?"

"Is my HTS code currently the subject of a pending BIS inclusion petition?" (Most brokers will need to check this specifically — it's not part of routine classification work unless you ask.)

Check both directions. Don't just check whether you're currently covered — check whether a near-neighbor classification is covered. If a very similar product one HTS line over from yours got added in a recent inclusion round, that's a signal your line is a plausible target for the next one. This is where the exposure audit (further down) becomes a standing document instead of a one-time check.

5. Melt-and-pour and smelt-and-cast reporting

If your product is covered, expect a second compliance burden layered on top of the duty itself: country-of-origin reporting for the underlying metal, independent of where the finished product was manufactured or assembled.

Melt and pour (steel). For steel articles, CBP requires reporting of the country where the steel was melted and poured — meaning the country where the raw steel was first produced from iron ore or scrap in its initial solid steel form. This is not the same as "country of origin" for the finished product and not the same as where the product was fabricated, stamped, or assembled. A part stamped in Country A from steel coil melted and poured in Country B has two different country data points, and CBP wants the melt-and-pour one for 232 purposes.

Smelt and cast (aluminum). The aluminum equivalent requires reporting the country where the aluminum was smelted (primary aluminum production from alumina) and where it was most recently cast into the form used in your product. Aluminum supply chains are frequently multi-country — smelted in one country, cast in another — so both data points can matter.

What this means for your supplier relationships. You cannot get this data by guessing or by relying on "Made in [Country]" on a commercial invoice — that label typically reflects where the finished good was produced, not where the metal was melted/poured or smelted/cast. You need your supplier (or their mill) to provide melt-and-pour or smelt-and-cast certification, ideally per shipment or per lot, in a format your broker can attach to the entry. If your supplier can't produce this documentation, that's a real problem — not a paperwork nuisance, but a signal that either (a) they don't have visibility into their own upstream supply chain, or (b) the metal is coming from a country whose disclosure they'd rather you not see closely.

Start this conversation before you need it. The worst time to discover your supplier can't produce melt-and-pour documentation is the week your broker asks for it to clear an entry. Build it into your supplier onboarding and periodic requalification process now, for every supplier whose product touches steel or aluminum content — even ones not currently on a derivative list, because Section 3 already told you that can change three times a year.

6. Calculating what you'll actually owe

For derivative articles assessed on content value, the math has three moving pieces: total entered value, the steel/aluminum content value within it, and the applicable 232 rate. Here's a worked, illustrative example — use your own verified current rate, not the number below, for real decisions.

Scenario: You import a steel-frame outdoor furniture set. Entered value: $40,000 per shipment (100 units at $400 landed cost each). Your supplier's bill of materials shows the steel frame components represent 35% of the manufactured cost of each unit.

| Step | Calculation | Result | |---|---|---| | Total entered value | 100 units × $400 | $40,000 | | Steel content share | 35% of unit cost, per supplier BOM | 35% | | Steel content value | $40,000 × 0.35 | $14,000 | | Illustrative 232 derivative rate (verify current rate before use) | applied to content value only | e.g., 50% | | Section 232 duty owed | $14,000 × 0.50 | $7,000 | | Normal Ch. 1–97 duty (separate, still owed) | e.g., 3.4% of full $40,000 | $1,360 | | Total duty burden, this shipment | 232 duty + standard duty | $8,360 |

That $7,000 is money you were very possibly not pricing into this SKU six months ago, and it lands on top of — not instead of — your normal duty. It also, per Section 9, cannot be recovered through drawback even if the finished goods are re-exported.

The part importers get wrong most often: the content-value percentage is not something you get to eyeball. You need it substantiated — a bill of materials, a supplier cost breakdown, or an engineering specification that ties the steel or aluminum weight/cost to a defensible share of total value. CBP can and does request support for content-value calculations, and "we estimated it" is not a great answer in a request-for-information letter. If your supplier won't give you a BOM-level cost breakdown, get your customs broker or a trade attorney to help you build a defensible methodology before you need it in an audit, not during one.

Run this table for every SKU you flagged in Section 4 as covered or borderline. If you don't know your content-value percentage today, that's the first gap to close — not after your next entry, before it.

7. The 30-day response cycle when a new inclusions window opens

Section 3 told you the windows exist. Here's what to actually do when one opens, on a day-by-day basis. This assumes a roughly two-week submission window followed by a comment period — adjust to the actual dates BIS publishes for the specific cycle, which you should be tracking per Section 10.

Day 0 — window opens. BIS publishes the opening of a new submission window, typically via Federal Register notice and posting on the BIS Section 232 program page. This is your trigger event. If you're not watching for it directly, your first signal will be a trade-press summary days later — don't rely on that as your primary source.

Days 1–3 — pull the petition list and screen your HTS codes. As petitions get filed and posted, cross-reference the HTS codes named against your own product catalog and near-neighbor codes. This is a fast triage pass: is anything you import, or anything one line away from what you import, named in a pending petition?

Days 4–14 — file comments or rebuttals if your code is targeted. If a petition names a code you rely on, this is your window to submit a comment opposing (or shaping) the inclusion. See Section 8 for what actually moves the needle in these comments. Don't wait for the "official" comment period to start drafting — get your data and argument built the moment you spot the petition, because these windows move fast relative to how long it takes to assemble supply-chain evidence.

Days 15–30 — scenario-plan pricing and sourcing regardless of outcome. Whether or not you commented, use this stretch to model what happens if the petition is granted: recalculate your content-value duty exposure (Section 6), identify whether alternate sourcing or product re-engineering (Section 9) is realistic before an effective date hits, and flag the SKU to whoever owns pricing so a duty increase doesn't surface as a surprise margin hit next quarter.

This cadence repeats roughly three times a year. Put it on a calendar with named dates, not a vague "check periodically" reminder — vague reminders are how importers end up hearing about coverage from their broker instead of from BIS.

8. Commenting against an inclusion petition

Most SMB importers assume commenting is pointless — that these are foregone conclusions driven by domestic producer lobbying. Sometimes that's closer to true than anyone would like. But BIS decisions in this process are still built around a stated national-security and import-surge rationale, and comments that engage with that rationale on the merits carry more weight than complaints about cost.

What tends to persuade, based on the stated criteria BIS and Commerce have used in Section 232 determinations generally:

Domestic availability arguments. If the domestic industry cannot actually supply the specific derivative product at the volume, spec, or price the market needs, that's directly relevant to a national-security-based coverage decision — the theory of the whole program is protecting domestic capacity that matters to security, not domestic capacity in the abstract. Evidence: RFQs to domestic suppliers showing no bids, no capacity, or lead times incompatible with your industry's needs; documented quality or certification failures from domestic sourcing attempts.

National-security nexus (or lack of one). Petitions are strongest when they can tie the product to a security-relevant supply chain. Comments are strongest when they can show the opposite — that a product (say, a decorative furniture bracket) has no plausible national-security dimension distinguishable from thousands of unrelated consumer goods.

Import-surge data, examined honestly. If the petition claims a surge in imports of the derivative product is displacing domestic production, real trade data (Census/USITC import statistics) either supports or undercuts that claim. Don't just assert it's wrong — bring the numbers.

Downstream harm with specifics. Generic "this will hurt small business" comments get discounted. Comments with actual numbers — units affected, jobs at your specific facility, price increases you'll have to pass to specific customer segments — read as evidence, not lobbying.

What doesn't move the needle much: pure cost complaints without domestic-availability evidence, comments filed after the window closes, and comments that don't cite the specific HTS lines under petition.

Practically: if you're a solo SMB importer, you may not have the bandwidth to build a full comment on your own. This is where industry associations earn their dues — a trade association comment backed by member data carries more weight than one company's letter, and it's worth finding out now (not during a live 14-day window) whether your industry has one that tracks these petitions.

9. Mitigation levers

If your product is covered — or about to be — here's what's actually available to you, and what isn't.

Sourcing shifts. Moving to a supplier whose steel or aluminum has different country-of-melt/pour or smelt/cast origin can matter if country-specific rates or quotas apply, but the base derivative-article duty generally applies regardless of country once a product is on the covered list (country distinctions matter more for the underlying metal tariffs and any negotiated country arrangements than for whether the finished derivative is covered at all). Verify current country-specific treatment before assuming a sourcing switch solves the problem — it may reduce your rate, or it may do nothing if the derivative coverage itself is country-agnostic.

Product re-engineering to reduce content value. Because duty on many derivatives is assessed on steel/aluminum content value, a legitimate engineering change that reduces the metal's share of total value — substituting a different structural material for non-load-bearing components, redesigning to use less metal by weight, shifting value into non-metal finishing or electronics — can directly reduce the duty base. This has to be a real engineering and cost change, documented as such; cosmetic reclassification without an actual product change is the kind of thing that draws CBP scrutiny.

First-sale valuation on the content value. If your supply chain has a qualifying multi-tiered sale (factory → trading company → you), first-sale valuation can lower the customs value used as your duty base under the standard rules — and where content value is calculated as a percentage of that customs value, a properly substantiated first-sale program can meaningfully lower your 232 exposure too. This requires real documentation (arm's-length sales, no post-importation price adjustments back to the factory price) — it's a legitimate program, not a loophole, and it needs a broker or trade counsel who's built one before.

FTZ — manage expectations here. Foreign-Trade Zones do not let you dodge Section 232 duties on covered goods. Goods subject to Section 232 that are admitted into an FTZ are generally required to be admitted in privileged foreign status, which locks in the duty rate and classification as of the date of admission to the zone — you don't get the benefit of duty deferral turning into duty avoidance through zone processing. An FTZ can still help with cash-flow timing and logistics, but don't build a mitigation plan around FTZ status making the duty disappear.

No drawback. Duty drawback — the mechanism that lets importers recover duties paid on goods that are later exported or destroyed — is not available for Section 232 duties. This has been a consistent feature of the program since 2018 and it means the "we'll just re-export the excess inventory and claim it back" plan does not work here, unlike with many ordinary Chapter 1–97 duties.

The honest summary: there's no clean escape hatch. The real leverage is upstream — sourcing, engineering, and valuation — combined with early warning (Section 10) so you're making these changes on your own timeline instead of during a duty-shock scramble.

10. Building a standing monitoring habit

Everything above assumes you know when something changes. Here's how to actually know.

Federal Register alerts. Set up a saved search or email alert on federalregister.gov for Section 232 steel and aluminum notices. This is the primary-source publication point for proclamations, BIS inclusion determinations, and window openings — not a summary written days later.

BIS's own Section 232 program page. bis.doc.gov maintains the current program information, including derivative product lists and, when active, information on the inclusions process submission windows. Check it on a schedule, not "when something feels off."

Broker SLAs, made explicit. Don't assume your customs broker is proactively watching this for you unless you've asked and gotten a yes in writing. Ask directly: "Will you notify me if a new BIS inclusion determination affects any HTS code I currently import, within how many business days?" Get that as an explicit service commitment, not an assumption baked into the relationship.

Why annual check-ins fail. If your compliance process is "we review our tariff exposure once a year," you will structurally miss this. The inclusions process runs on roughly three cycles per year — an annual review means you're checking in on a list that has already changed two or three times since your last look, with effective dates and duty liability that may already be behind you. The gap between "when the window opened" and "when your annual review happens" is where the $7,000 surprise duty bill in Section 6 comes from.

The realistic target: a standing watchlist tied to your actual HTS codes, checked against every BIS inclusion window as it opens — not a person's memory, not an annual calendar reminder, but a system that flags a match the day it becomes public. That's the only cadence that matches how the program actually moves in 2026.

The 232 Exposure Audit

A working checklist — run this now, then re-run it every time a new inclusions window closes.

List every HTS code you currently import, including near-neighbor codes for products you're considering sourcing or reclassifying.

Check each code against current Chapter 99 flags (9903.8x-range provisions) using hts.usitc.gov or your broker's live classification tool — not a saved list from a prior quarter.

Estimate steel/aluminum content value for each covered or borderline SKU, backed by a supplier bill-of-materials or cost breakdown, not a guess.

Get melt-and-pour (steel) or smelt-and-cast (aluminum) documentation from every supplier whose product contains meaningful steel or aluminum content, before you need it for an entry.

Calendar the next BIS submission window and the resulting comment period, with named dates, not a vague quarterly reminder.

Assign an owner — one named person responsible for checking the Federal Register/BIS page on the window's opening day and running the Day 0–30 cycle in Section 7. "Someone should watch this" is not an assignment.

Run steps 1–4 today if you haven't. Steps 5–6 are what keep this from becoming a one-time exercise you forget about until the next surprise duty bill.

Related reading: TariffWatch Section 232 checker Section 232 vs 301 vs MTB comparison First Sale valuation hidden traps How to draft a Section 232 comment letter

FAQ

Is there still a product exclusion process for Section 232? Historically, yes — BIS ran a formal exclusion-request process starting in 2018, later supplemented by General Approved Exclusions and country-specific tariff-rate quotas for some trading partners. As derivative coverage expanded through 2025, the exclusion landscape shifted significantly and, for a number of product categories, exclusion pathways were curtailed or eliminated as broader tariff-rate-quota and derivative-coverage mechanisms took their place. Treat "there's no exclusion process anymore" and "there's a robust exclusion process" as both potentially wrong depending on your specific product and country — verify current exclusion availability for your exact HTS code directly with BIS or your broker before assuming either way.

Do Section 232 duties stack with Section 301 duties? Yes, generally. Section 232 (national security) and Section 301 (unfair trade practices, primarily China-focused) are separate legal authorities, and where a product is covered by both, the duties are typically layered on top of each other and on top of your normal Chapter 1–97 duty rate. There's no automatic offset between them. If you import steel or aluminum derivative goods from China, check your exposure under both programs — not just one.

Can I get duty drawback on Section 232 duties? No. Drawback recovery has not been available for Section 232 duties since the program began in 2018, and that hasn't changed with the derivative expansions. If your mitigation plan relies on exporting or destroying excess inventory to claim duties back, that plan doesn't work for the 232 portion of your duty bill — plan your inventory and sourcing decisions accordingly.

What is "melt and pour"? It's the country where raw steel was first produced in solid form — from iron ore or scrap, at the mill — as distinct from where a finished product was stamped, assembled, or shipped from. CBP requires this data point reported on covered steel entries because a product can be "made in" one country while its underlying steel was melted and poured in a completely different one, and 232 treatment can turn on that upstream fact.

What's the aluminum equivalent of melt and pour? Smelt and cast — the country where primary aluminum was smelted from alumina, and the country where it was most recently cast into the form used in your product. Aluminum supply chains frequently split these two steps across different countries, so both need documentation.

How do I know if my HTS code is on a "derivative" list right now? Check the current Chapter 99 provisions tied to your specific 10-digit HTS number at hts.usitc.gov, and ask your broker directly whether an active steel/aluminum derivative overlay applies to it. Don't rely on a general sense of "my product isn't really a steel product" — many currently-covered derivative articles (furniture hardware, fasteners, appliance parts) don't look like steel products to a layperson either.

If my product isn't covered today, can I assume it's safe? No. That's the central point of this article. Coverage expands through the BIS inclusions process on a recurring cycle — roughly three windows per year — so "not covered today" only tells you about today. Products get added by petition, not by you doing anything differently. The only real protection is watching the windows, not a one-time classification check.

How is the duty actually calculated on a derivative article — full value or content value? For many derivative products, it's assessed on the steel or aluminum content value within the product, not the full entered value — see the worked example in Section 6. But this varies by specific product category and rule, so confirm the valuation basis for your exact HTS code rather than assuming content-value treatment applies universally.

Can product re-engineering actually reduce my duty? Yes, if it's a genuine change that reduces the actual steel/aluminum content share of the product's value, and it's documented as a real engineering and cost change. It's not a paperwork trick — CBP can and does scrutinize valuation claims that look like reclassification without substance.

Who actually gets to petition for a new inclusion, and can I find out who's filing them? Petitions are generally filed by domestic producers or their industry associations — the parties who benefit from expanded coverage. Petitions filed during an open submission window are posted publicly by BIS, which is exactly why Section 7's Day 1–3 triage matters: the information is public before it's binding, and that gap is your entire warning window.

Primary sources

19 U.S.C. § 1862 (Section 232) — statutory authority.

BIS 232 exclusion portal (BIS.doc.gov) — official exclusion filing entry point.

Related reading

Section 232 steel tariffs — 2026 complete rate guide

How the Aug 27 2026 BIS comment window affects metals importers

How to draft a Section 232 comment letter that gets read

TariffWatch — Section 232/301 monitoring & alerts

TariffWatch pricing

FAQ

Is there still a product exclusion process for Section 232?

Historically, yes — BIS ran a formal exclusion-request process starting in 2018, later supplemented by General Approved Exclusions and country-specific tariff-rate quotas for some trading partners. As derivative coverage expanded through 2025, the exclusion landscape shifted significantly and, for a number of product categories, exclusion pathways were curtailed or eliminated as broader tariff-rate-quota and derivative-coverage mechanisms took their place. Treat "there's no exclusion process anymore" and "there's a robust exclusion process" as both potentially wrong depending on your specific product and country — verify current exclusion availability for your exact HTS code directly with BIS or your broker before assuming either way.

Do Section 232 duties stack with [Section 301](https://ustr.gov/issue-areas/enforcement/section-301-investigations) duties?

Yes, generally. Section 232 (national security) and Section 301 (unfair trade practices, primarily China-focused) are separate legal authorities, and where a product is covered by both, the duties are typically layered on top of each other and on top of your normal Chapter 1–97 duty rate. There's no automatic offset between them. If you import steel or aluminum derivative goods from China, check your exposure under both programs — not just one.

Can I get duty drawback on Section 232 duties?

No. Drawback recovery has not been available for Section 232 duties since the program began in 2018, and that hasn't changed with the derivative expansions. If your mitigation plan relies on exporting or destroying excess inventory to claim duties back, that plan doesn't work for the 232 portion of your duty bill — plan your inventory and sourcing decisions accordingly.

What is "melt and pour"?

It's the country where raw steel was first produced in solid form — from iron ore or scrap, at the mill — as distinct from where a finished product was stamped, assembled, or shipped from. CBP requires this data point reported on covered steel entries because a product can be "made in" one country while its underlying steel was melted and poured in a completely different one, and 232 treatment can turn on that upstream fact.

What's the aluminum equivalent of melt and pour?

Smelt and cast — the country where primary aluminum was smelted from alumina, and the country where it was most recently cast into the form used in your product. Aluminum supply chains frequently split these two steps across different countries, so both need documentation.

How do I know if my HTS code is on a "derivative" list right now?

Check the current Chapter 99 provisions tied to your specific 10-digit HTS number at hts.usitc.gov, and ask your broker directly whether an active steel/aluminum derivative overlay applies to it. Don't rely on a general sense of "my product isn't really a steel product" — many currently-covered derivative articles (furniture hardware, fasteners, appliance parts) don't look like steel products to a layperson either.

If my product isn't covered today, can I assume it's safe?

No. That's the central point of this article. Coverage expands through the BIS inclusions process on a recurring cycle — roughly three windows per year — so "not covered today" only tells you about today. Products get added by petition, not by you doing anything differently. The only real protection is watching the windows, not a one-time classification check.

How is the duty actually calculated on a derivative article — full value or content value?

For many derivative products, it's assessed on the steel or aluminum content value within the product, not the full entered value — see the worked example in Section 6. But this varies by specific product category and rule, so confirm the valuation basis for your exact HTS code rather than assuming content-value treatment applies universally.

Can product re-engineering actually reduce my duty?

Yes, if it's a genuine change that reduces the actual steel/aluminum content share of the product's value, and it's documented as a real engineering and cost change. It's not a paperwork trick — CBP can and does scrutinize valuation claims that look like reclassification without substance.

Who actually gets to petition for a new inclusion, and can I find out who's filing them?

Petitions are generally filed by domestic producers or their industry associations — the parties who benefit from expanded coverage. Petitions filed during an open submission window are posted publicly by BIS, which is exactly why Section 7's Day 1–3 triage matters: the information is public before it's binding, and that gap is your entire warning window.