Section 232 Metals Technical Correction: Why 9903.82.01 Matters

Quick Answer

The current Section 232 metals family is now 9903.82.01-.26, not just 9903.82.02-.19.

USITC posted 2026 HTS Revision 7 on April 29, 2026. Its modification source is the Federal Register technical-corrections notice for Proclamation 11021. CBP then issued CSMS #68554727 on May 6, confirming that new heading 9903.82.01 is active in ACE. The heading applies to articles listed in U.S. note 16(c) that do not contain aluminum, steel, or copper and carries a 0% additional ad valorem Section 232 rate.

USITC posted 2026 HTS Revision 9 on May 28, 2026. CBP then issued CSMS #68855869 on June 5 for June 8 implementation of new 9903.82.20-.26 metals headings, value-based U.S./non-U.S. content reporting, the 85% by-weight U.S. metal test for "entirely" treatment, and the Section 122 interaction for 9903.82.03, 9903.82.13, and 9903.82.21. The key 9903.82.01 technical-correction change for this page still traces back to Revision 7 and CBP's May 6 ACE guidance.

Informational only - not legal advice.

What changed

On April 2, 2026, the metals proclamation restructured Section 232 aluminum, steel, and copper treatment into the 9903.82.* family for entries on or after April 6.

On April 29, Commerce/BIS published technical corrections to that proclamation's HTS implementation. The first correction added 9903.82.01.

On May 6, CBP confirmed the new heading is active in ACE.

Timeline	Event
April 2, 2026	White House issued Proclamation 11021 for aluminum, steel, and copper.
April 6, 2026	Restructured metals duties became effective.
April 29, 2026	Federal Register technical corrections published at 91 FR 23056.
April 29, 2026	USITC posted 2026 HTS Revision 7.
May 6, 2026	CBP issued CSMS #68554727 confirming `9903.82.01` in ACE.
May 22, 2026	USITC posted 2026 HTS Revision 8 with `9903.82.01-.19` in the metals family.
May 27/28, 2026	CBP and the Federal Register published Taiwan Section 232 implementation guidance that references `9903.82.02` and `9903.82.04-.19` for qualifying Taiwan civil aircraft components; that does not change the `9903.82.01` technical-correction rule.
May 28, 2026	USITC posted 2026 HTS Revision 9, the latest observed USITC release page in this review.
June 1/4, 2026	Proclamation 11032 / Federal Register 2026-11314 added June 2026 Section 232 metals modifications, including new headings `9903.82.20-.26`.
June 5/8, 2026	CBP CSMS #68855869 provided ACE implementation guidance for entries on or after June 8, 2026.

What 9903.82.01 means

9903.82.01 covers:

Articles provided for in subdivision (c) of U.S. note 16 to this subchapter that do not contain any aluminum, steel, or copper.

Its additional Section 232 rate is 0%.

That does not mean the entry is duty free. It means the specific Section 232 metals additional duty does not apply under that correction heading. The entry can still have:

base Chapter 1-97 duty,
other Chapter 99 overlays,
merchandise processing fee,
harbor maintenance fee,
AD/CVD,
other reporting or documentation requirements.

Why this matters for entry review

If a page, spreadsheet, or internal model says current Section 232 metals are only 9903.82.02-.19 or 9903.82.01-.19, it is stale.

Use this current framing:

Period	Metals code framing
Before April 6, 2026	Legacy metals families such as `9903.78.`, `9903.80.`, `9903.81.`, and parts of `9903.85.`
April 6-June 7, 2026	Consolidated metals family `9903.82.01-.19`, plus Russian aluminum-specific `9903.85.67-.68`
June 8, 2026 and later	Consolidated metals family `9903.82.01-.26`, with new `9903.82.20-.26` headings for the June 2026 metals changes, plus Russian aluminum-specific `9903.85.67-.68` where applicable

9903.82.01 is not the main duty heading

Most covered aluminum, steel, copper, and derivative entries will not use 9903.82.01. The new heading is for listed articles that do not contain aluminum, steel, or copper and therefore receive a 0% additional Section 232 rate under the technical correction.

The Tata Steel UK clarification

CBP's May 6 guidance also clarifies treatment for U.K.-origin steel articles made by Tata Steel UK when the reported country of melt and pour is the Netherlands. CBP states those articles may continue to be declared under 9903.82.04 until January 1, 2028, and may count toward the 95% steel melted-and-poured requirement under note 16(d) for headings 9903.82.04 and 9903.82.05 until that date.

That is a narrow origin/melt-and-pour clarification. Do not generalize it to unrelated U.K. steel entries.

Importer checklist

If your entries include post-April 6 Section 232 metals lines:

Confirm whether the entry is using a current 9903.82.* heading or a legacy metals heading.
If the goods do not contain aluminum, steel, or copper, ask whether 9903.82.01 should have been used.
Preserve the base Chapter 1-97 HTS number, country of origin, metal content records, melt-and-pour or smelt-and-cast data, and Chapter 99 lines.
Keep Russian aluminum headings 9903.85.67-.68 separate from the consolidated 9903.82.* family.
Watch for broker corrections or CBP guidance if an entry used 9903.82.03 or another heading before the technical correction was implemented in ACE.
For June 8, 2026 and later entries, preserve both value-based U.S./non-U.S. reporting support and by-weight metal-content support because CBP's June guidance separates the Canada/Mexico split from the 85% "entirely from" metal test.

Common mistakes

Listing current metals as 9903.82.02-.19 or 9903.82.01-.19 and omitting the June 2026 9903.82.20-.26 headings.
Treating 9903.82.01 as a refund guarantee rather than a classification/filing correction issue.
Applying the post-April 6 9903.82.* family to entries before April 6.
Applying the June 8 9903.82.20-.26 headings to earlier entries.
Treating the Tata Steel UK clarification as a general U.K. steel rule.
Assuming a 0% Section 232 heading means no other duties or fees are owed.

Litigation status

As of June 8, 2026: No filed challenge to the April 2026 Section 232 metals proclamation (Proclamation 11021), the April 29, 2026 technical-corrections notice, or the June 2026 metals proclamation identified in this review. Section 232 has a longer track record of upheld presidential tariff authority than IEEPA, but importers should still monitor for filings.

Frequently Asked Questions

What is HTS 9903.82.01?

HTS 9903.82.01 is a Section 232 metals technical-correction heading for articles listed in U.S. note 16(c) that do not contain aluminum, steel, or copper. It carries a 0% additional ad valorem duty.

Did Section 232 metals change from 9903.82.02-.19 to 9903.82.01-.26?

Yes. USITC 2026 HTS Revision 7 and CBP CSMS #68554727 added 9903.82.01. USITC 2026 HTS Revision 9 and CBP CSMS #68855869 now carry the current metals family through 9903.82.26.

Does 9903.82.01 eliminate all duties?

No. It is a zero-additional-duty Section 232 heading. It does not erase base duty, other Chapter 99 duties, fees, AD/CVD, or other entry obligations.

When is the technical correction effective?

CBP describes the 9903.82.01 technical correction as retroactive for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on April 6, 2026. Separate June 2026 Section 232 metals changes took effect June 8, 2026.