legal update·5 min read

Section 232 Metals Technical Correction: Why 9903.82.01 Matters

USITC Revision 7 and CBP CSMS #68554727 added 9903.82.01 to the current Section 232 metals family. Here's what the zero-additional-duty heading means.

By Paige W.··Updated May 8, 2026

Quick Answer

The current Section 232 metals family is now 9903.82.01-.17, not just 9903.82.02-.17.

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.

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.

TimelineEvent
April 2, 2026White House issued Proclamation 11021 for aluminum, steel, and copper.
April 6, 2026Restructured metals duties became effective.
April 29, 2026Federal Register technical corrections published at 91 FR 23056.
April 29, 2026USITC posted 2026 HTS Revision 7.
May 6, 2026CBP issued CSMS #68554727 confirming 9903.82.01 in ACE.

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-.17, it is stale.

Use this current framing:

PeriodMetals code framing
Before April 6, 2026Legacy metals families such as 9903.78.*, 9903.80.*, 9903.81.*, and parts of 9903.85.*
April 6, 2026 and laterConsolidated metals family 9903.82.01-.17, plus Russian aluminum-specific 9903.85.67-.68

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:

  1. Confirm whether the entry is using a current 9903.82.* heading or a legacy metals heading.
  2. If the goods do not contain aluminum, steel, or copper, ask whether 9903.82.01 should have been used.
  3. 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.
  4. Keep Russian aluminum headings 9903.85.67-.68 separate from the consolidated 9903.82.* family.
  5. 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.

Common mistakes

  • Listing current metals as 9903.82.02-.17 and omitting 9903.82.01.
  • 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.
  • 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 May 8, 2026: No filed challenge to the April 2026 Section 232 metals proclamation (Proclamation 11021) or to the April 29, 2026 technical-corrections notice 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.

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Informational only — not legal advice. RefundArrow is not a law firm, and this resource does not create an attorney‑client relationship with Himmelstein & Adkins, LLC. Tariff/refund outcomes depend on your facts, entry records, and evolving CBP/court guidance; consult qualified customs counsel for advice on your situation.

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