At present, importers and customs brokers are operating in an environment where CBP has not issued formal, binding guidance that prescribes a single valuation methodology. As a result, valuation practices are being shaped through a combination of published FAQs and operational communications issued during compliance activity.

Why metal valuation remains complex:

The complexity does not stem from whether metal content must be declared, but from how that value is determined within different supply chain structures.

Challenges most commonly arise where goods are composed entirely of steel or aluminium but undergo additional processing prior to importation, as well as where finished products contain a mix of metal and non-metal components. In these scenarios, questions often arise around how various costs are treated within the declared value of the metal content.

CBP’s current communications on valuation:

CBP has indicated that the value of steel and aluminium content should be determined in accordance with established customs valuation principles, focusing on the price paid or payable for the metal itself and excluding international transportation and insurance costs.

In addition, CBP operational teams have communicated valuation expectations through post-entry reviews and Notices of Action. These communications indicate that, in practice, CBP may assess duties on the full entered value for goods composed entirely of steel or aluminium, without deducting costs associated with manufacturing, labour, coatings, or processing. For goods containing both metal and non-metal components, CBP communications have reflected an approach where the metal value is derived from the total entered value minus the identifiable cost of non-metal components.

Status of CBP guidance:

At this time, CBP has not issued a formal ruling or decision that establishes a legally binding methodology for valuing steel and aluminium content under Section 232 or IEEPA tariffs.

Recent valuation-related communications have been issued through operational channels, including Notices of Action and compliance correspondence. While these communications may be encountered during reviews, they do not constitute published regulatory guidance or precedent-setting rulings.

Importers retain the ability to seek clarification through established CBP processes, including protests, internal advice requests, and binding ruling applications.

Documentation and information requests:

During compliance reviews, CBP has been requesting detailed supporting information related to metal content valuation. Requests have included explanations of valuation methodology, cost analyses, supplier documentation, invoices, packing lists, product schematics or diagrams, photographs, and confirmation of importer awareness of the declared approach.

These requests reflect CBP’s focus on understanding how metal content values are determined and supported within the import documentation.

Monitoring future developments:

CBP has indicated that further clarification may be issued in the future. Importers and industry participants are encouraged to continue monitoring official CBP communications, rulings, and trade notices as they become available.

Woodland Group update:

Woodland Group continues to monitor developments related to Section 232 and IEEPA tariffs and their application. We will provide updates as additional information or clarification is released by CBP.

If you have questions regarding regulatory developments impacting your supply chain, our customs and trade teams are available to discuss current considerations.