Section 232 Steel & Aluminum Compliance

Client

A U.S.-based importer of industrial equipment and manufactured components sourced from multiple international suppliers.

Challenge

Following the expansion of Section 232 steel and aluminum tariffs, the client began experiencing inconsistencies in how duties were being applied to imported products that contained steel or aluminum components.

Many multinational brokerage providers were applying the 232 tariff to the full value of the product, rather than calculating duties based only on the actual steel or aluminum content within the finished product. This occurred because entries were being processed without the necessary data to properly calculate the material content within each item.

As a result, importers faced two significant risks:

• Overpayment of duties when tariffs were incorrectly applied to 100% of the product value
• Compliance exposure if entries lacked the required material breakdown and supporting documentation

The client needed a structured process to determine the correct steel and aluminum value within each product, apply the appropriate tariff rate, and ensure that entries remained compliant with Section 232 reporting requirements.

Solution

J.M. Rodgers worked closely with the client to build a compliance-focused workflow designed to correctly apply Section 232 duties while improving operational efficiency.

The process included:

• Collaborating with the client to collect and map product-level data, including the steel and aluminum content within each imported product
• Developing a data mapping structure linking part numbers, material composition, and tariff applicability
• Creating a process to calculate the correct dutiable value for steel and aluminum components rather than applying tariffs to the entire product value
• Building internal workflows to help automate the calculation process where possible within the entry preparation stage
• Implementing manual compliance reviews and audits of entries to ensure the correct tariff application and supporting data accuracy

This approach allowed the client to integrate compliance controls into their import process while maintaining efficiency for high shipment volumes.

Outcome

• Correct application of Section 232 duties based on actual steel and aluminum content
• Reduced risk of overpaying tariffs due to incorrect duty calculations
• Improved compliance documentation supporting customs entry filings
• Increased internal visibility into how tariffs impacted product-level landed costs

The client now has a structured process that balances automation with manual oversight, ensuring entries remain compliant while improving operational efficiency.

Key takeaways

Section 232 tariffs require material-level data and calculations, not simply applying tariffs to the full product value

• Many import errors occur when product composition data is not properly integrated into entry preparation
• Automation can improve efficiency, but manual compliance review remains critical for complex tariff programs
• Importers benefit from brokers who provide strategic compliance support, not just entry processing