Trade and origin data

Country of melt, from the mill certificate to the entry line

Section 232 duty on steel and aluminium derivatives is assessed on the value of the metal content. Where that value is unknown, it is assessed on the entire entered value instead. That makes it a bill of materials problem with a price attached, and no mid market ERP has a field for it.

The problem

If you cannot state the metal content value, duty is assessed on the whole thing

That is the rule, and it is the entire reason this is a data problem rather than a customs problem.

For steel and aluminium derivative articles, Section 232 duty applies to the value of the metal content. Where that content value is less than the entered value, the metal and non-metal content are reported on separate entry summary lines.

Where the content value is unknown, or equal to the entered value, the duty is reported on the entire entered value, on a single line.

So not knowing has a price, and it is charged automatically, on every entry, without anyone telling you. A broker cannot fix it for you, because the number has to come out of your bill of materials.

What has to be reported

Three things, per entry line

Country of melt and pourFor steel and steel derivatives, as an ISO country code. Where the steel was melted and poured in the United States, that is reported as US.
Country of smelt and castThe equivalent for aluminium derivatives. CBP guidance provides for reporting unknown where it genuinely is not known, which is not a position you want to be filing from repeatedly.
The metal content valueWhich decides whether you file one entry line or two, and therefore what you pay duty on.

Why it is hard

The data exists, on paper, in the wrong place

Country of melt arrives on the mill test certificate, per heat. It is correct, it is specific, and in most plants it goes into a filing cabinet or a scanned PDF folder and is never seen again.

To file correctly it has to travel: from goods in, onto the lot or heat record, through every bill of materials that consumes that lot, into the finished article, and out to the broker as a number per entry line. Four handoffs, and most mid-market ERPs do not have a field for it at the first one.

It also moves. Change supplier, or take a different heat from the same supplier, and the answer changes. It is not a value you set once on the item master and forget, which is exactly how most people first try to solve it.

And unlike an annual filing, this is every shipment.

What we build

A path for the number, from the mill certificate to the entry line

Capture at goods inCountry of melt and the mill certificate reference recorded against the lot or heat, at receipt, by the person already handling the paperwork. Usually a field and a scan, not a project.
Roll up through the bill of materialsSo a finished article's metal weight by type, and the origin of that metal, are computable rather than reconstructed. This is the part that does not exist in your ERP today.
An export your broker can file fromMetal content value and non-metal value per line, with the ISO codes attached, in the shape the entry summary needs.
A gap reportWhich lots on hand have no country of melt recorded, so you find out before an entry does.

This is normally a few weeks of work rather than a system replacement, because the ERP keeps doing everything it already does. We are adding one attribute and making it survive the journey.

Being straight with you

What this page does not say

There are no duty rates here, and no US content percentage threshold. Section 232 was restructured in April 2026 and expanded again in June 2026, and the secondary sources currently disagree with each other on the threshold figure. We are not going to publish a number that the people reading this page can check faster than we can.

We are not customs brokers and we do not give tariff advice. Your broker rules on what is filed. We build the thing that lets you hand them a defensible number instead of a shrug.

Primary guidance lives in CBP's CSMS messages, including #65236374, #65236645 and #68253075. Those are the documents to check, and the ones we work from.

FAQ

Common questions

Is this not something our customs broker handles?

Your broker files the entry, but they can only file what you give them. Country of melt and metal content value originate in your receiving and your bill of materials, not in theirs. A broker asking you for those figures and getting an estimate is the situation this fixes.

Our ERP has a country of origin field. Is that not the same thing?

No, and conflating them is the most common error we see. Country of origin is where the article was made. Country of melt and pour is where the steel in it was melted, which is frequently a different country, and is tracked per heat rather than per part.

What happens if we genuinely do not know?

For aluminium, CBP guidance allows reporting that the country of smelt or cast is unknown. The practical consequence of not knowing your metal content value is different and more expensive: duty is assessed on the entire entered value rather than on the metal content alone.

How long does this take to build?

Usually a few weeks, not a quarter, because nothing is being replaced. The work is a field at goods in, a roll up through the bill of materials, and an export. The longest part is normally agreeing who records the certificate and when.

Which ERPs do you do this in?

We have built this kind of attribute and roll up alongside Epicor, Infor CloudSuite and SyteLine, Business Central, NetSuite, Sage and QuickBooks based setups. The pattern is the same; where it differs is how the ERP lets you extend the lot record and get data out.

Keep exploring

Related