Last updated: October 12, 2026

Oil and gas equipment imports: who holds the Importer of Record role on tubular goods, drilling equipment, and the parts behind them

Oil country tubular goods, line pipe, drill pipe, wellhead and pressure equipment, pumps, compressors, and the parts that keep a rig running enter the United States under a Section 232 regime that, since April 6, 2026, assesses duty on the full customs value of the article. Casing and tubing carry the 50 percent steel rate. Many of the machines and parts around them sit in the derivative tiers at 50 or 25 percent, or in the combined 15 percent tier for listed trading partners. Antidumping and countervailing duties apply on top for many tubular products. The party that declares the classification, the country where the steel was melted and poured, the value, and the heading that sets the rate, and that pays all of it, is the Importer of Record (IOR). This page is for procurement, compliance, and finance leaders at operators, service companies, equipment manufacturers, and distributors who bring that equipment in. It sets out the duties in force, who typically holds the IOR role in the supply chain, what that party must declare and license, and where the 2026 customs enforcement order points.

The Section 232 duties in force on oil and gas equipment

Proclamation 9705 of March 8, 2018, published at 83 FR 11625, defined steel articles at the six digit level to include 7304.10 through 7306.90, which covers seamless and welded oil country tubular goods, line pipe, and other tubes and pipes. Proclamation 10947 of June 3, 2025 raised the rate from 25 to 50 percent effective June 4, 2025. Proclamation 11021 of April 2, 2026, published at 91 FR 18201, rebuilt the regime effective April 6, 2026: its first clause provides that the duties apply to the full customs value of the imported product regardless of metal content, and its annexes set the rates by tier. Proclamation 11032 of June 1, 2026, published at 91 FR 34085 and effective June 8, 2026, added the combined 15 percent tier for products of listed trading partners and the Canada and Mexico content rule. CBP’s filing guidance is CSMS #68253075 of April 3, 2026 and CSMS #68855869 of June 5, 2026.

What that means for the equipment on a rig:

The August 18, 2025 additions came through the Bureau of Industry and Security notice at 90 FR 40326, which added 407 classifications as steel and aluminum derivatives. Proclamation 11021 ended that petition process and provides that the Secretary of Commerce and the United States Trade Representative may add further derivative articles on a rolling basis by Federal Register notice, so the right hand column of this table can change on a published date. The steel and aluminum page carries the full heading table, the United Kingdom, United States metal, and Canada and Mexico tiers, and the January 1, 2028 transition.

Three further points sit on top of the Section 232 duty. CBP’s FAQ states that Section 232 duties may not be waived due to a free trade agreement and that GSP and AGOA may not be claimed on these entries. Manufacturing drawback under 19 U.S.C. §1313(a) and (b) is available only for articles in the second and third annexes of Proclamation 11021 that are products of a trade agreement partner with metal melted and poured in a trade agreement partner, and no other drawback is available. And antidumping and countervailing duties continue to apply, which CBP’s guidance states expressly; oil country tubular goods and line pipe from a number of countries are covered by orders, and the deposit rates attach to the same entry.

The temporary import surcharge under section 122 of the Trade Act of 1974, imposed by Proclamation 11012 at 10 percent from February 24, 2026, did not apply in addition to Section 232 duties and exempted energy and energy products. Executive Order 14389 of February 20, 2026 ended the duties that had been imposed under the International Emergency Economic Powers Act, and CBP processes refunds of those duties to the Importer of Record through its CAPE declaration process. Section 232 and Section 301 duties were unaffected by that order.

Who holds the Importer of Record role in an oil and gas 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 oilfield supply the role sits in one of three places.

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, and who answers for the antidumping and countervailing declarations that CBP examines most closely on tubular products. 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 an oilfield 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 application reports the importer, exporter, and manufacturer, the country of origin, the Chapter 72 or 73 classification, the quantity in kilograms, the customs value, and the country where the steel was melted and poured. A license is valid for 75 days.

Melt and pour. CBP’s guidance directs filers to continue reporting the countries of melt and pour for all subject steel and steel derivative products, following CSMS 64348411, 64348288, and 65340246, and the CBP FAQ states that ACE requires the melt and pour country on any line with a derivative classification even where the article contains no covered steel. Under 19 C.F.R. §360.103 the country of melt and pour is where the raw steel was first produced in a liquid state in a steel making furnace and poured into its first solid shape. For tubular goods that is the mill that cast the billet or slab, which is not always the mill that rolled, threaded, or coupled the pipe.

Classification and antidumping and countervailing declarations. Oil country tubular goods, line pipe, and drill pipe are classified by process, alloy, wall thickness, and outside diameter, and the same classification decides whether an antidumping or countervailing duty order applies and at what deposit rate. The Importer of Record declares the case number and rate on the entry, posts the deposit, and holds the entry open until liquidation.

Foreign trade zones. Products subject to Proclamation 11021 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, and the license requirement applies at admission.

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 test certificates and origin documents behind the melt and pour report, the license, the antidumping and countervailing declarations, 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.

Valuation decides the duty

A 50 percent duty on full customs value, with antidumping or countervailing deposits on top, makes the declared value the largest number on an oilfield entry. 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, dies, and engineering supplied by the buyer, for royalties, and for proceeds, and with exclusions for charges that are not part of the price of the goods, such as international freight and insurance where they are separately identified.

Oilfield procurement puts the method in play in three ways. Equipment bought from a related mill or an affiliate’s trading company is a related party transaction, and transaction value applies only where the relationship did not influence the price. Goods bought under master supply agreements with volume rebates, inspection and testing charges, or threading and coating performed by a third party raise the question of what is part of the price and what is not. And where transaction value cannot be used, the statute moves in order 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 oil and gas importers

The duty base changed from steel content to full customs value on April 6, 2026, which matters most for the machinery and parts in the derivative tiers, where steel is a fraction of the value. The scope grew through the August 2025 additions and the June 2026 annexes, and rolling additions by Federal Register notice replaced the petition process. The general tariff landscape moved when Executive Order 14389 ended the duties imposed under the International Emergency Economic Powers Act and Proclamation 11012 imposed a temporary surcharge that did not reach Section 232 goods or energy products.

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. The enforcement order tracker carries the current position of each directive. A foreign mill entering tubular goods under a 50 percent duty and an antidumping deposit is the kind of importer the bonding and vetting directives describe.

Frequently asked questions

Related

• Steel and aluminum imports: the Importer of Record under Section 232
• What an Importer of Record is responsible for
• Customs valuation under 19 U.S.C. §1401a
• Who needs a US Importer of Record
• Pharmaceutical imports: the Importer of Record under Section 232
• What changed in 2026: the enforcement order tracker
• Nonresident importer in the United States
• How it works

Sources

• Proclamation 9705, Adjusting Imports of Steel Into the United States, 83 FR 11625, March 15, 2018
• Proclamation 10947, Adjusting Imports of Aluminum and Steel Into the United States, 90 FR 24199, June 9, 2025
• Bureau of Industry and Security, Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process, 90 FR 40326, August 19, 2025
• Proclamation 11021, Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States, 91 FR 18201, April 9, 2026
• Proclamation 11032, Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States, 91 FR 34085, June 4, 2026
• CBP, CSMS #68253075, Guidance: Section 232 Duties on Imports of Aluminum, Steel, and Copper, April 3, 2026
• CBP, CSMS #68855869, Guidance: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper, June 5, 2026
• CBP, Section 232 Steel and Aluminum Articles FAQs
• Proclamation 11012, Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems, 91 FR 9339, February 25, 2026
• Executive Order 14389, Ending Certain Tariff Actions, 91 FR 9437, February 25, 2026
• CBP, IEEPA Duty Refunds
• 19 C.F.R. §360.101, steel import licensing
• 19 C.F.R. §360.103, automatic issuance of import licenses
• 19 U.S.C. §1484, entry of merchandise
• 19 U.S.C. §1401a, value
• 19 U.S.C. §1508, recordkeeping
• 19 U.S.C. §1592, penalties
• 19 C.F.R. §141.18, entry by nonresident corporation
• Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125, June 10, 2026
• CBP, Accuracy of Importer of Record Data Submitted to CBP, Federal Register, August 19, 2026

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.