Section 232 Inclusion Request - Ellwood Group

A Section 232 measure is a U.S. trade action based on a finding that imports of a particular product may threaten national security. The measure can apply to covered merchandise based on its tariff classification, product description, country of origin, and any stated exclusions or special rules. “232” refers to Section 232 of the Trade Expansion Act of 1962; it is separate from ordinary customs duty rates and other trade remedies.

This type of measure typically affects importers, manufacturers, distributors, and retailers bringing covered goods into the United States. The importer of record is generally responsible for making the entry declaration and paying applicable duties or other import charges. It matters because the product’s classification, origin, customs value, and eligibility for an exclusion or exemption can affect whether the measure applies. A customs broker or trade attorney may be needed when the scope or documentation is unclear.

What to check

• Confirm the product’s full Harmonized Tariff Schedule (HTSUS) classification, not just its commercial name, and compare it with the measure’s covered tariff provisions and product scope.
• Verify the country of origin under U.S. customs rules; the shipping country is not necessarily the origin, and special rules may apply to substantially transformed goods.
• Check the official measure instructions for exclusions, exemptions, quota treatment, reporting requirements, and any country-specific provisions.
• Review the entry data with your customs broker, including the applicable Chapter 99 reporting provisions, customs value, and supporting product records.
• Keep technical descriptions, bills of materials, origin records, invoices, and any exclusion or authorization documentation in case Customs and Border Protection requests support.