What is Section 232 and why does it matter for steel, aluminum, and copper imports?

Section 232 of the U.S. Trade Expansion Act allows the president to impose tariffs if imports threaten national security. Since 2018, this has led to significant tariffs on steel and aluminum, and in 2025, copper was added. Importers must now provide detailed supply chain data (such as country of smelt, cast, melt, and pour) to avoid duties up to 200%.

How can importers stay compliant with Section 232 reporting requirements?

Importers should:Collect mill test certificates, certificates of analysis, or supplier attestationsEngage suppliers early to ensure smelt/melt data is availableUse trade compliance software to trace metals back to the smelterWork with compliance experts to interpret CBP updates and avoid costly penalties

What are the risks of not complying with Section 232 tariff requirements?

If importers cannot prove the country of smelt, cast, melt, or pour, U.S. CBP may assume the material originated from a restricted country (such as Russia). This can trigger a 200% duty, shipment delays, or even having goods stopped at the border. Lack of documentation creates significant financial and operational risks.

What does country of origin (COO) mean?

COO indicates where a product was produced or manufactured. All imports require clear marking of COO, ensuring transparency and accountability for goods crossing borders. It’s the basis for everything from standard customs clearance packets to tariff analysis to compliance with regulations such as the Uyghur Forced Labor Prevention Act (UFLPA). On top of that, a part’s COO determines whether the product or part is eligible for preferential treatment under certain trade agreements.

Why is accurate country of origin data important?

Accurate country of origin data helps avoid shipment delays, unexpected tariffs, and fines. For some materials like steel or aluminum, importers must also report the country of smelt, pour, or cast — not just where the product was assembled.

How can manufacturers stay compliant with country of origin rules?

To meet country of origin compliance requirements, manufacturers need traceable, up-to-date part-level data. Using automated trade compliance software helps collect certificates of origin, assign the correct HS/HTS codes, and keep up with changing trade regulations.

Why are tariffs a major concern for manufacturers in 2025?

Tariffs have become one of the biggest obstacles to manufacturing growth. According to the National Association of Manufacturers, 76% of companies cited trade uncertainty as their top concern in early 2025: a 20% jump from late 2024.At the same time, manufacturers expect raw material costs to rise more than 5%, largely due to shifting global tariffs and supply chain disruptions. These new trade barriers are forcing companies to reassess sourcing strategies, supplier dependencies, and cost structures. Uncertainty around import duties, Section 232 tariffs, and global trade agreements means manufacturers need accurate supply chain visibility to forecast costs and stay competitive.

How can supply chain data help manufacturers lower tariff costs and qualify for tariff exclusions?

With accurate country of origin (COO) and harmonized tariff schedule (HTS) data, manufacturers can apply for tariff exclusions, qualify for free trade agreements (FTAs), and even reduce customs duties. But approvals only go to manufacturers with verifiable COO and HTS data to prove eligibility. The substantial transformation rule also allows tariff reductions when parts from multiple countries are assembled into a product that undergoes significant change but this is only valid with traceable supply chain data.

How does Assent help manufacturers manage tariffs and trade compliance more effectively?

Assent helps manufacturers navigate complex tariff requirements and trade regulations through a combination of expert guidance and AI-driven technology. Our platform automates the collection of COO and HTS data, improves supply chain visibility, and ensures compliance with trade regulations, including Section 232, Dodd-Frank Section 1502, and global FTAs.With the largest supply chain data network in the industry, Assent gives you:Accurate COO and HTS data managementAutomated supplier outreach and educationGuidance from trade compliance expertsProven processes for securing tariff exclusions and cost savings