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Last updated: October 27, 2026

Steel and aluminum imports: who holds the Importer of Record role under the 2026 Section 232 regime

Since April 6, 2026, Section 232 duties on steel, aluminum, and their derivative products apply to the full customs value of the imported article regardless of metal content, at rates of 50 percent, 25 percent, or a combined 15 percent depending on the article, the country of origin, and where the metal was melted and poured or smelted and cast. The party that declares all of that, pays the duty, and holds the records is the Importer of Record (IOR). This page is for compliance, procurement, and finance leaders at companies that import steel mill products, aluminum, fabricated metal, machinery, equipment, and the hundreds of derivative articles now inside the scope. It sets out the duties in force, who typically holds the IOR role in a metals supply chain, what that party must declare and license, and where the 2026 customs enforcement order points.

Steel beams and slabs stacked in a mill yard, the kind of covered steel mill product that needs an import license and a melt and pour report from the Importer of Record

The short version

  • Proclamation 11021 of April 2, 2026 moved the Section 232 steel, aluminum, and copper duties onto the full customs value of the imported product, effective April 6, 2026, and ended the inclusions process in favor of rolling additions by Federal Register notice.
  • The default rate on aluminum and steel articles and the main derivatives is 50 percent. A second tier of derivatives carries 25 percent. A third tier carries a combined column 1 and Section 232 rate of 15 percent through December 31, 2027.
  • Proclamation 11032 of June 1, 2026, effective June 8, set a combined 15 percent rate for products of listed trading partners, a 25 percent duty on only the non United States content of USMCA qualifying goods from Canada and Mexico, and lowered the United States metal threshold from 95 to 85 percent by weight.
  • Every entry of covered steel reports the country where the steel was melted and poured, every entry of covered aluminum reports where the metal was smelted and cast, and basic steel mill products need a Commerce import license under 19 C.F.R. Part 360 before the entry summary is filed.
  • The duties cannot be waived under a free trade agreement. Drawback is limited. Antidumping and countervailing duties apply on top.

On this page: the duties in force, who holds the IOR role, what the IOR declares and licenses, valuation, what changed in 2026, questions.

The Section 232 duties in force today

The steel and aluminum duties date from Proclamations 9705 and 9704 of 2018, issued under 19 U.S.C. §1862. Proclamation 10947 of June 3, 2025 raised them from 25 to 50 percent effective June 4, 2025, with the United Kingdom held at 25 percent, and at that time the duty on derivative articles applied only to their steel or aluminum content. Two 2026 proclamations rebuilt the regime.

Proclamation 11021, Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States, signed April 2, 2026 and published at 91 FR 18201, took effect for goods entered on or after 12:01 a.m. eastern time on April 6, 2026. Its first clause states that the duties apply to the full customs value of the imported product, regardless of metal content. It set the rates by annex, terminated the inclusions process, and provided that the Secretary of Commerce and the United States Trade Representative may add derivative articles on a rolling basis by Federal Register notice. CBP’s filing guidance is CSMS #68253075 of April 3, 2026.

Proclamation 11032, Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States, signed June 1, 2026 and published at 91 FR 34085, took effect June 8, 2026. It created a further annex of articles at 25 percent, a combined 15 percent rate for products of Argentina, Ecuador, El Salvador, Guatemala, Japan, South Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, and the member nations of the European Union, a 25 percent duty on only the non United States content of USMCA qualifying products of Canada and Mexico with a total duty of not less than 15 percent, and an 85 percent threshold by weight for an article to count as made entirely of United States metal. It added aluminum lithographic plates and steel racks as derivative products and placed agricultural equipment and residential HVAC equipment in the 15 percent category. CBP’s guidance is CSMS #68855869 of June 5, 2026.

The headings CBP uses, as of the June 2026 guidance:

HeadingRateWho it covers
9903.82.0250 percentArticles of aluminum, steel, or copper and the main derivatives
9903.82.030 percentArticles outside Chapters 72, 73, 74, and 76 whose covered metal is under 15 percent by weight; the metal weight is reported on the line
9903.82.04 and .0525 and 15 percentUnited Kingdom articles and derivatives, where the metal was melted and poured or smelted and cast in the United Kingdom
9903.82.07 and .0810 percent floorDerivatives whose metal was melted and poured or smelted and cast in the United States
9903.82.10 and .1115 percent combined floor, through December 31, 2027The third tier of derivatives, where the column 1 rate is below 15 percent
9903.82.1225 percentDerivatives from countries without normal trade relations
9903.82.14 to .1750, 25, and 10 percentSteel, copper, and derivative steel from Russia; Russian aluminum stays at 200 percent under Proclamation 10522
9903.82.18 and .1925 percentSteel and aluminum entered by the single Importer of Record designated under an approved Proclamation 10984 production commitment
9903.82.20 and .2125 and 0 percentUSMCA qualifying derivative steel from Canada and Mexico, reported on two lines: non United States content, and United States content up to 40 percent of entered value
9903.82.2215 percentProducts of the listed trading partners

On January 1, 2028 the articles under headings 9903.82.07 through .12 move to the rates under .05, .06, and .09. Goods containing more than one covered metal are subject to the duty once. Products admitted to a foreign trade zone on or after April 6, 2026 must be admitted in privileged foreign status under 19 C.F.R. §146.41 unless eligible for domestic status under 19 C.F.R. §146.43. Manufacturing drawback under 19 U.S.C. §1313(a) and (b) is available only for articles in the second and third annexes that are products of a trade agreement partner with metal melted and poured or smelted and cast in a trade agreement partner, and no other drawback is available. CBP’s FAQ states that the duties may not be waived due to a free trade agreement and that GSP and AGOA may not be claimed on these entries.

Who holds the Importer of Record role in a metals supply chain

On every formal entry one party is named as Importer of Record. Under 19 U.S.C. §1484 that party must be the owner or purchaser of the goods, or a licensed customs broker they designate, and it carries the duties, the bond, the records, and the reasonable care obligation. In steel and aluminum trade the role sits in one of three places.

The foreign mill or fabricator, selling delivered duty paid

The producer enters the goods in its own name as a nonresident importer under 19 C.F.R. §141.18, with a resident agent and a bond from a resident surety. It owes a 50 percent duty on the full value of its own shipments, holds the steel import license, and reports its own melt and pour country. Its Form 5106 is the one the September 18, 2026 accuracy enforcement examines.

The United States buyer, processor, or distributor

A service center, fabricator, original equipment manufacturer, or distributor buys the goods and enters them. The declared value is its purchase price, or a related party price where the mill is an affiliate, and it is this party that reports melt and pour, claims any reduced heading, and answers a CBP request for the records behind the claim.

A United States Importer of Record provider

Where neither the producer nor its customer holds the role, a United States company with the right to make entry is named on the entry under a shipment-specific authorization. The provider holds its own IOR number, bond, license registration, and records, and it must be able to support the melt and pour report, the metal content claim, and the value on every line.

Which party holds the role decides who carries a duty that is now larger than the price of many of the goods it attaches to. The who needs a United States Importer of Record page compares the situations side by side.

What the Importer of Record must declare and license on a metals entry

The steel import license. Under 19 C.F.R. §360.101, all entries for consumption of covered basic steel mill products, and all admissions of covered products into a foreign trade zone, require a Commerce Department steel import license before the entry summary or admission documents are filed. Informal entries are exempt. Under 19 C.F.R. §360.103 the license application reports the importer, exporter, and manufacturer, the country of origin, the Chapter 72 or 73 classification, the quantity and customs value, and the country where the steel used in the product was melted and poured. A license is valid for 75 days, and a low value license covers shipments valued under 5,000 dollars.

Melt and pour, smelt and cast. CBP’s guidance directs filers to continue reporting the countries of melt and pour for all subject steel and steel derivative products and the countries of smelt and cast for all aluminum and aluminum derivative products, following the instructions in CSMS 64348411, 64348288, and 65340246. The CBP FAQ states that ACE requires the melt and pour or smelt and cast country on any line with a derivative classification, even where the article contains no covered metal. Those reports are what the reduced United Kingdom and United States metal headings rest on.

Metal content and United States content. A claim under heading 9903.82.03 reports the aggregate weight of the covered metal in kilograms on the entry summary line. A claim under the United States metal headings requires that at least 85 percent by weight of the article’s metal content was melted and poured or smelted and cast in the United States, a threshold Proclamation 11032 lowered from 95 percent. For USMCA qualifying goods from Canada and Mexico, the entry carries two lines with the same classification and origin, one for the non United States content and one for the United States content, with special program indicator S on both. Proclamation 11032 states that where CBP determines an importer has engaged in fraud or deliberately misled the government about United States content, CBP shall impose penalties to the extent permitted by law.

Reasonable care and records. Under 19 U.S.C. §1484(a)(1) the IOR must use reasonable care in classifying the goods, declaring their value, and determining the rate of duty. Under 19 U.S.C. §1508 and 19 C.F.R. Part 163 it keeps the entry, the mill certificates and origin documents behind the melt and pour report, the weight and content evidence behind any reduced heading, the license, and the commercial documents for five years, and produces them under 19 U.S.C. §1509. Penalties under 19 U.S.C. §1592 attach to the Importer of Record, and antidumping and countervailing duties, which cover many steel and aluminum products, are reported on the same entry.

Valuation decides the duty

Until April 6, 2026 the duty on a derivative article fell on its steel or aluminum content. It now falls on the full customs value of the article. For a fabricated assembly, a machine, a rack, or an appliance inside the scope, the customs value, not the weight of metal, sets the duty.

Under 19 U.S.C. §1401a the customs value follows a sequential hierarchy of methods beginning with transaction value, the price actually paid or payable when sold for export to the United States, with statutory additions for assists such as tooling and dies supplied by the buyer, for royalties, and for proceeds, and with exclusions for charges that are not part of the price of the goods. Sales between a foreign mill and its United States affiliate are related party transactions to which transaction value applies only where the relationship did not influence the price. Where transaction value cannot be used, the statute moves through the transaction value of identical or similar merchandise, deductive value, computed value, and the fallback method under 19 U.S.C. §1401a(f). The customs valuation page walks through each method and what CBP examines. Whichever method applies, the Importer of Record declares it, and establishing and documenting the correct value is work done before importation.

What changed in 2026 for steel and aluminum importers

Three things moved in one year.

The duty base changed from metal content to full customs value on April 6, 2026, and the scope grew through the 2025 inclusions round, which added 407 classifications, and the June 2026 additions. Rolling additions by Federal Register notice replaced the petition process.

Country and content rules multiplied. The 15 percent combined rate for listed partners, the Canada and Mexico content split, the United Kingdom tiers, the United States metal tiers, the Proclamation 10984 production commitment program for producers in Canada and Mexico with a single designated Importer of Record, and the Proclamation 11045 aluminum onshoring incentive of July 20, 2026 each turn on facts the IOR declares and documents.

Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026 and published at 91 FR 35125, directs minimum tangible domestic assets or bonding for Importers of Record, heightened formal entry requirements for foreign entities, a good standing requirement with increased vetting, and a 50 percent minimum penalty floor. As of October 12, 2026 those directives remain in rulemaking with no effective date. The Form 5106 accuracy enforcement under the order has been in effect since September 18, 2026, and CBP voids the IOR number of any importer whose form lists a borrowed address or a third party’s contacts. The enforcement order tracker carries the current position of each directive. A foreign mill entering full container loads under a 50 percent duty is the kind of importer the bonding and vetting directives describe.

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Frequently asked questions

Is the Section 232 duty on a derivative article charged on the whole product or just the metal?

Since April 6, 2026, on the full customs value of the imported product regardless of metal content, under clause 1 of Proclamation 11021. Before that date the duty on derivative articles applied only to the steel or aluminum content.

Does USMCA remove the duty on steel from Canada or Mexico?

No. Under Proclamation 11032, effective June 8, 2026, USMCA qualifying derivative steel from Canada and Mexico pays 25 percent on its non United States content, with a total duty of not less than 15 percent, reported on two entry lines. CBP’s FAQ states that Section 232 duties may not be waived due to a free trade agreement.

Who needs a steel import license?

Under 19 C.F.R. §360.101 every consumption entry and every foreign trade zone admission of covered basic steel mill products requires a license before the entry summary is filed. Only informal entries are exempt. The license reports the country of melt and pour and is valid for 75 days.

What does melt and pour mean, and who reports it?

Under 19 C.F.R. §360.103 it is the country where the raw steel was first produced in a liquid state in a steel making furnace and poured into its first solid shape. The filer reports it on the entry for every subject steel and steel derivative line, and the Importer of Record answers for its accuracy and keeps the mill documents that support it.

Can a foreign steel or aluminum producer still be its own Importer of Record?

Yes, under 19 C.F.R. §141.18, with a resident agent in the state of the port of entry and a bond from a resident corporate surety. Since September 18, 2026 its Form 5106 must list its own address and contacts or CBP voids the IOR number, and Executive Order 14411 directs further requirements for foreign entities that remain in rulemaking.

Related

Sources

This page summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.

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