On June 13, 2025, U.S. Customs and Border Protection (CBP) issued updated guidance on reporting the country of smelt and cast for derivative aluminum imports subject to Section 232 tariffs. Effective June 28, 2025, importers who do not know the country of smelt and cast will be required to:

• Report “unknown” instead of the International Organization for Standardization (ISO) code for the unknown country of smelt and cast
• Report HTS 9903.85.67 or 9903.85.68, depending on the aluminum derivative product in question
• Pay a 200% Section 232 duty—the same duty assessed on aluminum imports originating from Russia

For aluminum and derivative aluminum imports whose country of smelt and cast is known, importers must report “Y” for the primary country of smelt and, if applicable, the secondary country of smelt. Importers cannot report “N” for both the primary and secondary countries of smelt. Additionally, importers must report the ISO code associated with the country of most recent cast.

Restoring a CBP Policy Instituted in March of 2025

On March 24, 2025, CBP issued a similar update for imports with an unknown or indeterminable country of smelt and cast. That update required the importer of record (IOR) to report Russia—and pay the resulting 200% Section 232 tariff—and then correct the entry via a post summary correction when the importer could definitively prove that Russia was not the country of smelt and cast. CBP walked back that update a few days later, allowing those importers to report another country and pay a 25% Section 232 duty instead.

With CBP’s most recent update announced on June 13, CBP’s March 24 policy is back.

What should importers note about the reinstitution of this policy? This time around, importers will be required to report Russia’s Chapter 99 HTS code as well—not just Russia as the country of smelt and cast.

How Will This Update Impact the Reporting Process?

In light of this upcoming update, Flexport’s customs brokers will file entries for derivative aluminum imports in line with the following:

• If the client indicates a particular country when asked for the country of smelt and cast, we will report that country at the time of filing.
• If the client indicates the United States as the country of smelt and cast, we will apply the exclusion for U.S.-produced aluminum.
• If the client indicates that the product contains 0% aluminum, we will report the country of smelt and cast in accordance with CBP’s FAQ instructions: “N/A” for the primary country of smelt, and the country of origin as the secondary country of smelt.
• If the client indicates that they do not know the country of smelt and cast, then we will follow up and advise them of CBP’s June 13 announcement, what CBP is expecting them to do, and encourage them to dig deeper. If the client still cannot confirm the country of smelt and cast, we will be obligated to report Russia, and the IOR will be subject to the resulting 200% tariff rate.

Flexport is also advising all clients to begin receiving and maintaining mill certificates as a compliance best practice, given the high duty rates and CBP’s heightened scrutiny in assessing “maximum penalties” on IORs who are not paying Section 232 duties.

Flexport’s customs and trade advisory experts can help businesses navigate any upcoming changes to shipments and customs entries, and provide up-to-date guidance on mitigating tariff impacts and disruptions. Please reach out to your account manager or advisory@flexport.com for more details.

In the meantime, check out Flexport’s recently launched Tariff Simulator. Calculate and analyze tariff impacts in real time, and forecast tariffs and landed costs for each shipment using real-time data and the latest duty rates and regulations.