Understanding Country of Smelt & Cast Requirements
Without knowing where your aluminum or steel comes from (smelted, melted, cast, or poured), you could face up to a 200% duty on your imports. That’s because U.S. Customs and Border Protection (CBP)’s requirements for declaring country of smelt and cast for aluminum and aluminum derivatives, and country of melt and pour for steel and its derivatives, are ramping up. As Section 232 tariffs on metal sourcing continue to evolve, there’s even more incentive to have reliable supply chain transparency and trade compliance documentation.
This article covers recent trade compliance updates and enforcement trends that go beyond what’s been officially declared. If you’re looking for guidance on what Section 232 means by country of smelt and cast and country of melt and pour, check out our glossary at the end of this article.
Here’s what you need to know about importing steel, aluminum, and copper under the new Section 232 requirements.
What Is Section 232?
The Trade Expansion Act was passed in 1962. Section 232 of the act permits the U.S. president to impose tariffs based on recommendations by the U.S. Secretary of Commerce, so long as “an article is being imported into the United States in such quantities or under such circumstances as to threaten or impair national security.” Section 232 famously paved the way for the sixth session of General Agreement on Tariffs and Trade (GATT) multilateral trade negotiations, also known as the “Kennedy Round.”
Section 232 has been used extensively by the Trump administration. In 2018, President Trump signed an order to impose a 25% imported steel tariff and a 10% levy on imported aluminum and its derivatives.
Recent Section 232 Updates
During President Trump’s second term, more updates to Section 232 have gone into effect:
- On June 4, 2025, the administration raised steel and aluminum tariffs to 50% from all countries except the UK, which remains at 25%
- On July 30, 2025, President Trump signed an executive order implementing a 50% tariff on semi-finished and intensive copper products as of August 1, 2025
- As of the time of this writing, copper does not have a country of melt and pour reporting requirement
Along with these Section 232 tariff actions on steel and aluminum, the administration has cracked down on the requirement for importers to report the country of smelt and cast for aluminum and its derivatives. The goal is to stop the flow of all aluminum and steel sourced from Russia.
While reporting the country of smelt and cast and melt and pour for these metals has been required for quite some time, importers were previously permitted to declare the country of smelt or melt as “unknown,” without any additional penalty.
However, on June 28, 2025, the Trump administration closed a loophole that took away this option, and requires a 200% duty to be paid for any aluminum or aluminum derivative articles if the country of smelt and cast cannot be effectively reported. If you can’t prove that the aluminum you’re importing is not from Russia, CBP will assume that it is and tariff you accordingly at 200%.
Trade Compliance Enforcement Beyond Section 232 Tariffs
Some Assent customers have had steel shipments stopped for declaring the country of melt and pour as “unknown.” And while this isn’t officially stated as a rule by CBP, it’s definitely not a bad idea to ensure you have proof of due diligence for steel and copper as well as aluminum to avoid the risk of receiving a 200% tariff in the future. As we’ve seen across the trade compliance landscape recently, changes are being announced and put into effect with very little notice.
As you can imagine, and may have already experienced, these sweeping tariffs have big impacts on the affected industries, and they present unique challenges to manufacturers that are trying to keep up. Make sure you have the correct documentation for these tariff increases, or you risk having shipments stopped or being levied at higher rates than necessary.
Demonstrating Country of Smelt or Melt to a Customs Agency
Certificates of analysis or mill test certificates from your supplier are key documents for proving country of smelt and cast. While CBP does not require these documents to be filed at time of entry for aluminum, they are authorized to request an aluminum certificate of analysis to ensure compliance. Importers are required to “exercise reasonable care” and must certify that their declared classification is consistent with the information and documentation provided.
Importers of steel and steel derivative goods have been required to report country of melt and pour since November 2024. The location of melt and pour is customarily identified on mill test certificates, which are generated at each stage of the steel production process. Mill tests include chemical composition, physical properties, mechanical properties, compliance information, and smelter information for the steel. They must be submitted via the Document Image System (DIS) in the Automated Commercial Environment (ACE) for applicable steel imports.
However, a formal attestation can also be provided by a supplier detailing the name and address of the smelting facility. A bill of lading or an invoice with the country of smelt clearly identified and labeled is also generally acceptable.
For more information on Section 232 tariffs, refer to the CBP’s FAQs.
Best Practices to Proactively Reduce Risk & Stay Compliant
As you can imagine, a reactive approach to CBP’s requirements is a recipe for compliance headaches. So how can you proactively manage these requirements, reduce your risks, and stay compliant?
Assent recommends four strategies that can help you achieve these goals:
- Robust supplier engagement, traceability across complex supply chains, and audit-ready documentation
- Proactively collecting smelt/melt data for steel, aluminum, and copper from suppliers upstream of country of origin data
- Implementing systems that can trace part-level supply chain data, including multi-sourcing countries of origin and smelter location
- Engaging trade compliance experts to interpret CBP’s evolving rules and guide strategy
How Assent Helps
You don’t have to navigate the complexities of Section 232 tariffs alone. Assent has the experience and the trade compliance software you need to handle your requirements and avoid tariffs so you can protect your revenue.
Assent’s responsible sourcing solution and team of regulatory experts can help you navigate today’s tumultuous trade environment and ensure you have the supply chain data to keep your products moving across borders. Our trade compliance solution enables multi-level country of origin collection, empowering you to trace metals back to the smelter and have supplier documentation on hand when you need it. With Assent, you can approach trade compliance with confidence.
To learn more about Assent’s supply chain data management solution and speak with a trade compliance expert, get in touch with Assent.
Section 232 Glossary
Country of Smelt & Cast — Aluminum
CBP’s reporting guidance for aluminum and aluminum derivatives requires importers to report three data points: primary country of smelt, secondary country of smelt, and country of cast.
- Primary country of smelt is defined as where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process
- Secondary country of smelt is defined as the country where the second largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process. If any smelting occurred in Russia and it was not stated as the primary country of smelt, it must be reported as the secondary country of smelt. For any products made of recycled aluminum, the country of origin can be reported as a secondary country of smelt
- Country of cast is defined as the country where the aluminum (with or without alloying elements) was last liquefied by heat and cast into a solid state. This final solid state can be semi-finished (slab, billet, ingot), or a finished product
While there may be multiple entities involved in the smelting and casting of a metal product, these data points are commonly consolidated into the term country of smelt and cast.
Country of Melt & Pour — Steel & Copper
For steel and its derivatives, CBP requires importers to report the country of melt and pour, defined as where the raw steel is initially melted into a liquid state and poured or cast into its first solid shape, such as a slab, billet, or ingot, or a finished steel mill product.
The same process and terminology of “melt and pour” applies to copper, which was recently added to the lineup of Section 232 metals. Although no requirements for reporting country of melt and pour have been set forth by CBP at the time of this writing, we would be remiss not to advise collecting this information from your suppliers along with steel and aluminum smelter data to stay ahead of any unpredictable changes to copper reporting requirements.
What’s the Difference Between Country of Smelt & Country of Origin?
Within the context of trade and according to rules of origin, a product’s country of origin (COO) is commonly understood to be where substantial transformation last occurred. An easy question to ask yourself to understand this difference is “did the HS code change?” If yes, then the product was substantially transformed and its COO is the country where that transformation occurred.
For example, say aluminum ingots are smelted and cast into aluminum sheets in Brazil. These sheets are then shipped to Mexico and shaped into stranded aluminum wire. These wires are subsequently shipped to the U.S. to be assembled into a final product. In this example, the COO for the U.S. importer is Mexico, but the country of smelt and cast is Brazil.
Learn more about HS codes and customs codes by downloading our expert guide, Customs Codes: Reducing Your Exposure to Tariffs & Audits.
