Section 232 Aluminum Tariffs: New Reporting Requirements for Importers

Introduction

In the ever-evolving landscape of international trade, staying informed about regulatory changes is crucial for businesses involved in importing goods. A recent update from U.S. Customs and Border Protection (CBP) regarding Section 232 aluminum tariffs has significant implications for importers. This article will delve into the new reporting requirements, their impact on the industry, and how FreightAmigo's Digital Logistics Platform can assist importers in navigating these changes.

On June 13, 2025, CBP issued updated guidance on reporting the country of smelt and cast for derivative aluminum imports subject to Section 232 tariffs. These changes, set to take effect on June 28, 2025, introduce new reporting requirements and potential financial implications for importers who are unable to determine the origin of their aluminum products.

Key Changes in Reporting Requirements

The new CBP guidance outlines several important changes that importers must be aware of:

• Importers who do not know the country of smelt and cast must report "unknown" instead of using an ISO code for an unknown country.
• These importers must report specific HTS codes (9903.85.67 or 9903.85.68) depending on the aluminum derivative product in question.
• A 200% Section 232 duty will be applied to imports with unknown origins - the same rate assessed on aluminum imports from Russia.
• For known origins, importers must report "Y" for the primary country of smelt and, if applicable, the secondary country of smelt. Reporting "N" for both is not allowed.
• The ISO code for the country of most recent cast must be reported.

Reinstatement of March 2025 Policy

This recent update effectively reinstates a policy that CBP briefly implemented in March 2025. Under that policy, importers were required to report Russia as the country of origin and pay the 200% tariff if the true origin was unknown or indeterminable. While this policy was quickly rescinded, allowing importers to report another country and pay a lower 25% duty, it has now been reintroduced with some modifications.

Impact on Importers

These changes have significant implications for importers of aluminum and derivative aluminum products:

1. Increased Due Diligence: Importers will need to conduct more thorough investigations into their supply chains to determine the country of smelt and cast for their aluminum imports.
2. Higher Potential Costs: The 200% duty rate for unknown origins represents a substantial financial risk for importers who cannot definitively prove the origin of their aluminum products.
3. Enhanced Record-Keeping: Maintaining detailed records, including mill certificates, will become increasingly important for compliance and potential duty disputes.
4. Potential Supply Chain Disruptions: Importers may need to reassess their supplier relationships and potentially seek new sources to ensure they can meet the new reporting requirements.

How FreightAmigo Can Help

As these new requirements add complexity to the import process, FreightAmigo's Digital Logistics Platform offers several features that can assist importers in navigating these changes:

1. Comprehensive Documentation Management: Our platform allows for easy storage and retrieval of important documents such as mill certificates, which will be crucial for compliance with the new reporting requirements.
2. Real-Time Tracking and Visibility: With connections to over 1000 airlines and shipping lines, FreightAmigo provides up-to-date information on shipment status, helping importers stay informed about their cargo at every stage of transit.
3. Customs Clearance Assistance: Our platform offers support for customs clearance processes, which can be particularly valuable as importers adjust to the new reporting requirements.
4. Expert Support: FreightAmigo provides 24/7 access to logistics experts who can offer guidance on regulatory changes and help importers develop strategies to minimize their impact.
5. Automated Document Generation: Our system can help automate the creation of necessary shipment documents, reducing the risk of errors in reporting and ensuring compliance with the new requirements.

Strategies for Importers

To adapt to these new requirements, importers should consider the following strategies:

1. Conduct a thorough review of your supply chain to identify any gaps in information about the origin of aluminum products.
2. Implement robust systems for tracking and documenting the country of smelt and cast for all aluminum imports.
3. Consider diversifying your supplier base to reduce reliance on sources with uncertain origins.
4. Invest in technology solutions, such as FreightAmigo's Digital Logistics Platform, to streamline documentation and reporting processes.
5. Stay informed about any further updates or changes to the Section 232 tariffs and reporting requirements.

Conclusion

The new reporting requirements for Section 232 aluminum tariffs represent a significant change for importers. While these changes may initially present challenges, they also offer an opportunity for businesses to improve their supply chain visibility and compliance processes. By leveraging digital solutions like FreightAmigo's platform, importers can navigate these new requirements more effectively, ensuring compliance while minimizing disruptions to their operations.

As the global trade landscape continues to evolve, staying agile and informed will be key to success. FreightAmigo remains committed to supporting our clients through these changes, providing the tools and expertise needed to thrive in an increasingly complex regulatory environment.