NEW 50% TARIFF ON COPPER IMPORTS (SEMI-FINISHED AND DERIVATIVE COPPER PRODUCTS) EFFECTIVE AUGUST 1, 2025 – SECTION 232 REQUIREMENTS

Effective August 1, 2025, all imports of semi-finished copper products and intensive copper derivative products will be subject to a new 50% ad valorem tariff under Section 232 of the Trade Expansion Act of 1962, as mandated by the White House Fact Sheet: President Donald J. Trump Takes Action to Address the Threat to National Security from Imports of Copper issued on July 30, 2025 and CSMS #657

94272 issued today, July 31, 2025.

This is a sweeping change that applies to all countries of origin and requires immediate attention for any importer whose goods may contain copper content, even as a component.

What’s Changing

·         HTSUS 9903.78.01: Imposes a 50% duty on the copper content of applicable products.

·         HTSUS 9903.78.02: Applies 0% duty to non-copper content or to products within subject headings that contain no copper. This allows for reciprocal and other tariffs to apply on the value not subject to copper tariffs.

·         If copper content cannot be specifically substantiated, CBP will assess 50% duty on the entire entered value.

Entry Filing Changes

When importing goods under any affected HTS number (listed below), importers and brokers must:

1. Break out the entry into two lines if the article is not purely copper:

   • Line 1 (Non-Copper Content):

     • Report using the applicable HTS from Chapters 1–97

     • Add HTS 9903.78.02

     • Report total quantity

     • Report value of non-copper content

     • Apply all other duties (e.g., IEEPA, AD/CVD, etc.)

   • Line 2 (Copper Content):

     • Repeat same Chapter 1–97 HTS

     • Add HTS 9903.78.01

     • Report 0 quantity

     • Report value of copper content only

     • Report second quantity in kilograms

     • Apply all other applicable duties

2. If composed entirely of copper:

   • Report a single line entry using HTS 9903.78.01 and pay 50% duty on the total entered value.

3. Documentation: You must maintain detailed documentation to substantiate copper content valuation (e.g., invoices, bills of materials, production records). If documentation is insufficient, CBP will assess the 50% duty on the entire value.

   
   

HTS Numbers Affected

This action applies to a wide range of copper products covered under the following tariff headings. If you are uncertain whether your product falls within this scope, you should contact us with a request for reports covering your goods. We are happy to provide you with this information as needed.

9903.78.01 and 9903.78.02: Applies to all imported semi-finished copper and intensive copper derivative products classified in below 8 digit headings:

Other Key Details

• Drawback is NOT available on duties imposed under this proclamation.

·         If an imported good is subject to both the Section 232 duties on automobiles and automobile parts under Proclamation 10908, as amended, and the Section 232 duties on copper and copper derivative products, then the Section 232 duties on copper and copper derivative products are not applicable.

·         Reciprocal Exclusion: International Emergency Economic Powers Act (IEEPA) Reciprocal tariff exception 9903.01.33 applies to goods subject to Section 232 tariffs including semi-finished copper and intensive copper derivative products provided for in 9903.78.01.

·         FTZ entries not eligible for domestic status must be entered as “privileged foreign status” as defined in 19 CFR 146.41

What You Should Do Now

• Review your tariff classifications for any items with potential copper content

• Confirm whether any of your imported products fall under the affected HTS headings

• Coordinate with your procurement teams to understand cost implications

• Maintain copper content valuation records for all applicable goods

• Contact our compliance team for entry planning and proactive declarations

For specific support or product reviews, please contact us at:

Rich@Fleischer-CHB.com

Management@Fleischer-chb.com

310.671.6402

We are actively monitoring all Section 232 regulatory actions and will continue to provide timely guidance. If you are uncertain whether your products are affected, please reach out immediately.