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- Trade Advisory: BIS Clarifies U.S. Content Calculation for USMCA Goods Subject to Section 232 Tariffs
- Impacto empresarial
- BIS clarifies how importers calculate U.S. content for qualifying Canadian and Mexican goods subject to Section 232 tariffs under USMCA.
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has issued new guidance to U.S. Customs and Border Protection (CBP) clarifying how “U.S. content” should be calculated for certain products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) and are subject to Section 232 tariffs.
The guidance implements the U.S.-content provisions of Presidential Proclamation 11032 of June 1, 2026, covering the Section 232 tariff regimes for steel, aluminum, and copper.
What Qualifies as U.S. Content?
Under the new BIS guidance, “U.S. content” includes:
The value attributable to parts that are: Wholly obtained in the United States; Entirely produced in the United States; or Substantially transformed in the United States.
To the extent not already included in the above calculation, the value attributable to: Steel melted and poured in the United States; Aluminum smelted and cast in the United States; and/or Copper smelted and cast in the United States.
The clarification provides importers with a more defined framework for identifying the U.S. content included in qualifying Canadian and Mexican products when determining the value subject to applicable Section 232 tariffs.
Effective Date
The guidance applies to covered products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on October 14, 2026.
Importer Considerations
Importers of affected Canadian and Mexican goods should review their supply chains and supporting documentation to determine whether they can identify and substantiate qualifying U.S. content.
Companies should consider:
- Identifying U.S.-origin parts and components incorporated into finished products;
- Reviewing manufacturing information relevant to whether components were substantially transformed in the United States;
- Identifying qualifying U.S.-produced steel, aluminum, or copper incorporated into the product;
- Maintaining documentation supporting the value attributed to U.S. content; and
- Coordinating with suppliers to obtain sufficient sourcing, production, and valuation information to support the calculation.
Importers should ensure that any U.S.-content value reported for customs purposes is supported by appropriate records.
How Crane Trade Consulting Can Help
Crane Worldwide Logistics can assist customers in evaluating the potential customs and trade-compliance implications of the new guidance and reviewing available product, sourcing, and import information to help determine how the guidance may apply to their transactions. For additional consultation on a case-by-case basis, please contact https://www.craneww.com/logistics-technology/tarfiff-response-unit/.
Disclaimer: This advisory is provided for informational purposes only and does not constitute legal advice. The information is based on publicly available government sources, including the U.S. Department of Commerce, Bureau of Industry and Security, guidance regarding the assessment of “U.S. content” under Proclamation 11032. Trade regulations, filing requirements, duty payment procedures, and administrative processes may be modified, clarified, or supplemented through subsequent Federal Register notices, CBP guidance, or other government actions. Importers should consult qualified legal counsel and trade compliance professionals before making decisions based on evolving customs compliance requirements.
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