…and what do exporters need to know?
These significant duty charges have already had a resounding impact on global trade, and it’s vital to have visibility of your supply chain, as Mike Court explains…
Section 232 tariffs are import duties imposed by the US government on certain goods to safeguard national security.
These tariffs, authorised under Section 232 of the Trade Expansion Act of 1962, are intended to protect US domestic industries deemed vital to national defence.
As of now, the US has imposed Section 232 tariffs on steel and aluminium, including derivative products, with a recent increase to 50% on 4th June 2025. Notably, the UK currently enjoys an exemption from this 50% tariff increase, enjoying a much lower, 25% rate. This exemption is, however, contingent on the UK’s adherence to the US-UK Economic Prosperity Deal (EPD).
Exporters will need to know their supply chains and, more immediately, the details of the Country of Smelt or Country of Melt and Pour.
These refer to the country where the raw material (such as aluminium, steel, and copper) was melted initially and poured into its first solid shape.
It’s important to note that the Country of Smelt, where the raw material is initially melted, is distinct from the Government of Origin or Country of Origin, where the final product is manufactured. For instance, a steel beam might be manufactured in the UK using steel that was smelted and cast in China.
Country of Smelt
Due to the high recycled content in the case of aluminium products, the Country of Smelt is taken to be the country where the majority of the new aluminium metal is produced from aluminium oxide (alumina) via the electrolytic Hall-Héroult process.
Country of Melt and Pour
For steel and steel-derived products, you will require the Country of Melt and Pour (COM), which refers to the location where the steel was originally produced in a steel-making furnace to pour from liquid state into its first solid form.
Country of Origin
Understanding duty calculations is an essential part of International Trade, so understanding the Country of Origin can affect the applicable tariffs and duties on US-imported goods.
UK businesses will need to track their supply chains
Knowing the country of Origin of Smelt helps trace the Origin of materials and can be vital for ensuring supply chain transparency and investigating potential circumvention of trade regulations.
US National Security Section 232 investigations often centre on the Origin of raw materials and their potential impact on US national security. The country of Smelt, therefore, plays a crucial role in these investigations.
You can find more information on Section 232 requirements by understanding where to obtain the following certificates:
- Mill test or material test certificates – These documents often include details about the country of Origin of the steel.
- Certificates of conformance, compliance, or analysis – These may also include the country of Origin of the Smelt.
- Metallurgical test reports and chemical analysis certificates – These can also provide the necessary information.
- Commercial invoices – In some cases, the country of Smelt might be mentioned on the commercial invoice.
What if you don’t have the right information?
From 28th June 2025, US importers unable to provide this information will be required to report “unknown” instead of the (ISO) code for Country of Smelt (or COM) and pay a 200% Section 232 duty, equivalent to duty applied to imports of aluminium from Russia.
If aluminium and derivative aluminium imports whose country of Smelting and casting is known, importers must report “Y” for the primary Country of Smelting and, if applicable, the secondary country of Smelting. Importers cannot report “N” for both the primary and secondary countries of Smelt. Importers must also report the ISO code associated with the country of the most recent cast.