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This article applies to:

  • Product: ONESOURCE Global Trade
  • Sub-Product: Cross-platform tools

Section 232 Metal Tariff FTZ Type 06 Entry Filing Guidance - 4/8/2026

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The findings below are based on our initial testing with CBP's ABI system following the April 6, 2026 Section 232 proclamation changes. CBP's system behavior is subject to change at any time without notice or published instructions. We will continue to monitor and update this guidance as new information becomes available.

Background

Effective April 6, 2026, significant changes were made to the Section 232 tariff framework affecting steel, aluminum, and copper. These changes introduced new Chapter 99 classifications and removed others. For FTZ Type 06 entries, the interaction between entry dates and privileged dates has produced some unexpected system behaviors in CBP's ABI system that customers need to be aware of when filing.

Key finding: Entry date vs. privileged date behavior

Our testing has revealed that CBP's ABI system is
not behaving consistently across all metal types
 when an entry date falls on or after April 6, 2026 with a privileged date prior to April 6, 2026. The behavior varies depending on the type of metal and whether the HTS is classified as a base metal or a derivative. The details are outlined below.

Behavior by metal and classification type

Non-Derivative Steel and Non-Derivative Aluminum
  • When filing with an entry date on or after April 6, 2026 and a privileged date prior to April 6, 2026, CBP's system is
    accepting the old pre-April 6 Section 232 Chapter 99 classifications
     for both non-derivative steel and non-derivative aluminum.
  • The metal declaration requirement is active and must be included on all applicable tariff lines.
  • This is the most straightforward scenario and appears to be functioning as expected from a regulatory standpoint.
Aluminum derivatives
  • When filing with an entry date on or after April 6, 2026 and a privileged date prior to April 6, 2026, CBP's system is
    accepting the old pre-April 6 Section 232 Chapter 99 classifications
     for aluminum derivatives.
  • The aluminum declaration requirement is active and must be included on all applicable tariff lines.
  • Attempting to use the new post-April 6 Chapter 99 classifications for aluminum derivatives with a pre-April 6 privileged date results in a full line rejection with a TRFF ADJSTMNT HTS NOT ALLOWED error.
    Do not use the new Chapter 99 classifications for pre-April 6 privileged layers.
Copper
  • When filing with an entry date on or after April 6, 2026 and a privileged date prior to April 6, 2026, CBP's system is
    accepting the old pre-April 6 Section 232 Chapter 99 classifications
     for copper.
  • The copper declaration requirement has
    not yet been implemented by CBP
    . There is no announced implementation date at this time. Customers should watch for a CBP CSMS message announcing when the copper declaration requirement will go live and be prepared to include it at that time.
  • Attempting to use the new post-April 6 Chapter 99 classifications for copper with a pre-April 6 privileged date results in a full line rejection.
    Do not use the new Chapter 99 classifications for pre-April 6 privileged layers.
Steel derivatives
  • This is the most problematic scenario identified in our testing. When filing with an entry date on or after April 6, 2026 and a privileged date prior to April 6, 2026, CBP's system is
    rejecting the old pre-April 6 Section 232 Chapter 99 classifications
     for steel derivatives. This is inconsistent with the regulatory intent of the privileged foreign status rules under 19 CFR 146.65.
  • Attempting to use the new post-April 6 Chapter 99 classifications with a pre-April 6 privileged date also results in rejection with a TRFF ADJSTMNT HTS NOT ALLOWED error.
  • Our testing has found that the only currently viable workaround for steel derivative HTS numbers with an entry date on or after April 6, 2026 and a pre-April 6 privileged date is to
    remove the Section 232 Chapter 99 entirely
     from the tariff line and file only with the applicable Section 122 Chapter 99.
  • The steel declaration requirement remains active and must be included regardless of which filing approach is used.
  • Please note
     this workaround is based solely on what CBP's ABI system is currently accepting. It does not represent regulatory guidance and customers should consult with their trade counsel regarding the duty implications of this approach. We are actively monitoring this situation and will provide updates as CBP issues further guidance.
Steel derivatives — Annex II removed items
  • HTS numbers that appeared on the Annex II removed list follow the same behavior as other steel derivatives described above.
  • Even though these HTS numbers are no longer subject to Section 232, CBP's system is still requiring a steel declaration for these items. This appears to be a CBP system implementation issue and we are tracking it closely.
  • The same workaround of removing the Section 232 Chapter 99 entirely applies here as well.

Important note on declaration requirements

Please read this section carefully.
While our testing has observed declaration requirements for steel and aluminum on the sample commodities we tested, CBP has implemented the metal declaration requirements
very inconsistently and without published guidance
. Whether a declaration is required on any given tariff line may depend on a number of factors, including but not limited to the specific commodity, the HTS number, and importantly,
when the privileged date was established
.
Customers should
not assume
 that because a declaration was not required on one commodity or entry that it will not be required on another. Equally, customers should
not assume
 that a declaration will always be required simply because our samples triggered one.
We strongly recommend that customers:
  • Confirm
     their specific commodities and HTS numbers individually with their trade counsel or CBP client representative, as declaration behavior may differ across commodities
  • Consult with their trade counsel regarding declaration requirements for their specific circumstances
  • Remain vigilant for any CBP CSMS messages that may provide additional guidance on declaration requirements
Regarding copper specifically — the copper declaration requirement has not yet been activated by CBP and no implementation date has been announced. Customers should monitor for a CBP CSMS message announcing the go-live date.

Split derivative filing

A split derivative filing occurs when a single commodity is reported across two separate tariff lines within an entry. This is required when the metal content portion of a single item has different Chapter 99 reporting requirements than the non-metal content portion of that same item. In this scenario, the commodity is effectively split into two tariff lines. One representing the metal content with its associated Chapter 99 classifications, and one representing the non-metal content.
Given the significant changes to the Section 232 framework effective April 6, 2026 and the inconsistent ABI system behavior we have documented above, there is currently an open question as to whether CBP will continue to accept split derivative filing for commodities that are entered on or after April 6, 2026 with a privileged date prior to April 6, 2026.
At this time:
  • We do not currently have a way to evaluate whether CBP's ABI system will accept split derivative reporting under this specific entry date and privileged date combination
  • Until guidance is received, we strongly recommend customers consult with their trade counsel before submitting entries that involve split derivative reporting for commodities with a privileged date prior to April 6, 2026 and an entry date of April 6, 2026 or later
We will communicate further on this topic as soon as guidance is available or additional testing can be completed.

Development team update — User update for 232 Metal IMCR deactivation

To help with the transition to the new Section 232 tariffs, we have delivered an optional mass maintenance tool to reduce manual effort when deactivating your expired 232 Metal IMCR rules. You may use this update or manage your IMCR rules.
Where to find it:
Tools > User Updates > 000 - Deactivate 232 Metal IMCR Rules
.
What it does:
 When run, this update will:
  • Identify all active Item Master Custom Rules (IMCR) that reference expired 232 Metal tariffs and are not matching on 232 Metal tariffs
  • Deactivate those rules by setting the End Effective Date to April 5, 2026
No new rules are created by this update.
When to use it:
 This update is intended for users who want to quickly remove expired 232 Metal IMCR rules before manually adding or uploading new rules for the updated 232 Metal tariffs.
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After running this update, you are responsible for ensuring appropriate Section 232 Metal IMCR rules are active for entries on or after April 6, 2026.
We are continuing to evaluate the 232 Metal changes and will provide additional tools and guidance as they become available. Please stay tuned for further updates.

Next steps

  • We are continuing to test additional scenarios with CBP and will update this guidance as findings develop.
  • We strongly recommend customers consult with their trade counsel regarding the regulatory implications of the filing approaches described above, particularly for steel derivative entries.
  • Watch for CBP CSMS messages regarding the copper declaration implementation date and any additional guidance on the April 6 Section 232 changes.
  • Further communication regarding the IMCR mass deactivation tool will follow once development is complete.
This document reflects testing conducted as of April 8, 2026. All findings are subject to change based on CBP system updates or published guidance.