The Man of Steel. Ruling with an iron fist. There are lots of expressions that use steel and iron as symbols of strength and toughness. But when it comes to importing into the U.S., the differences between the two are anything but symbolic.
Unfortunately, U.S. Customs and Border Protection doesn’t always make things easy. On March 15 CBP’s Base Metals Center of Excellence and Expertise issued revised—yet still unofficial—guidance on determining metal content for Section 232 purposes. That matters because since 2018 a vast number of metal products have been subject to steep Section 232 duties—50 percent for most steel imports. By contrast, certain iron products, including cast iron, pig iron, and wrought iron, remain exempt.
CBP’s latest guidance stresses that iron content should be determined the same way as other metals and that many iron-containing products are subject to Section 232. CBP also reiterated that references to steel and aluminum include alloys and reminded importers that while all steel contains iron, the chemistry of a steel article cannot be disaggregated to carve out a non-Section 232 iron component.
The guidance also walked through how Section 232 coverage has evolved. From the start of the tariffs in March 2018 through March 11, 2025, coverage was based solely on the HTSUS classification. Beginning in 2025, a large number of derivative products were added, significantly expanding and complicating coverage.
From March 12 through June 3, 2025, Section 232 still turned on tariff classification, but tariffs applied only to covered content for derivative articles classified outside Chapters 73 (iron and steel) and 76 (aluminum). Since June 4, 2025, iron articles and iron parts classified in Chapter 73—and iron content in derivative articles classified elsewhere—generally do not pay Section 232 tariffs. However, covered iron products in Chapter 72, as well as two iron-containing tariff lines in Chapter 87, remain subject to Section 232.
Confused yet? You’re not alone. These exemptions and exceptions are maddeningly complex. Classification is critical, and value calculations require careful analysis of inputs such as labor and packaging. The good news is that ST&R experts can help you make sense of it all for your imports.
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