On July 15, 2026, U.S. Customs and Border Protection (CBP) issued CSMS #69252300, providing guidance on the new reporting requirements for the countries of smelt and cast for imports of certain copper articles under Proclamation 11021. Beginning July 30, 2026, importers of specified copper wire and cable products will be required to submit smelt and cast country information through the Automated Commercial Environment (ACE).
Background
On April 2, 2026, President Trump issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. § 1862 (Section 232). Published in the Federal Register at 91 FR 18201, Proclamation 11021 built on prior Section 232 actions addressing aluminum (Proclamation 9704) and steel (Proclamation 9705), and extended and strengthened the tariff regime to cover copper articles and their derivatives.
Proclamation 11021, as previously reported here, imposed additional ad valorem duties of 10–50% on the full customs value of certain imports of copper articles from all countries, effective April 6, 2026. The Proclamation also directed importers to provide CBP with the information needed to identify; (1) the country where the copper used in covered imports was smelted; and (2) the country where the copper was cast, with CBP directed to implement these requirements “as soon as practicable.”
CBP’s earlier guidance set forth in CSMS #68253075 from April 3, 2026, had confirmed that smelt and cast country reporting would be required for copper products under certain HTSUS classifications and indicated that a future CSMS would announce when ACE functionality would be available.
New ACE Reporting Requirements
CSMS #69252300 states that effective July 30, 2026, importers of certain copper articles from all countries of origin (except the United States) must report the following on the entry summary line in ACE:
- Primary country of smelt: Required for all covered entries.
- Country of cast: Required for all covered entries.
- Secondary country of smelt: Optional but may be reported where applicable.
These fields must be submitted for the following Harmonized Tariff Schedule of the United States (HTSUS) classifications:
- 8544.42.10 – Insulated electrical conductors, for a voltage not exceeding 1,000V fitted with modular telephone connectors
- 8544.42.20 – Insulated electrical conductors, for a voltage not exceeding 1,000V fitted with connectors and of a kind used for telecommunications
- 8544.42.90 – Insulated electrical conductors, for a voltage not exceeding 1,000V fitted with other connectors
- 8544.49.10 – Insulated electrical conductors not fitted with connectors, of a kind used for telecommunications, and rated for a voltage not exceeding 80V
Where the primary country of smelt, secondary country of smelt, and/or country of cast are unknown, importers may report “OTH” (other) for any or all fields. While this provides a compliance option where full traceability is not yet available, importers should be aware that continued reliance on “OTH” may invite scrutiny. Separately, CBP also updated the ACE CATAIR Entry Summary Error Dictionary (V51) to add new error codes tied to copper smelt and cast reporting.
Importers and customs brokers should adjust filing workflows and training to account for these validations, as errors may result in entry delays or CBP requests for additional information.
Key Deadlines and Next Steps
CBP has identified two dates that should be tracked:
- July 16, 2026 (Certification environment): ACE functionality to accept the new copper smelt and cast fields will be deployed to the ACE certification environment.
- July 30, 2026 (Production environment): ACE functionality goes live in production, and reporting of the primary country of smelt and country of cast becomes mandatory for covered entries of the four HTSUS classifications listed above. Failure to report will trigger the new ACE CATAIR error codes.
With the July 30, 2026 deadline approaching, importers should take time now to: (1) confirm whether any imports are classified under HTSUS Subheadings 8544.42.10, 8544.42.20, 8544.42.90, or 8544.49.10; (2) collect and confirm primary smelt, secondary smelt (if applicable), and cast country information from suppliers; (3) test ACE reporting starting July 16; and (5) coordinate with brokers and internal teams to avoid filing errors and delays.
The Husch Blackwell International Trade and Supply Chain team continues to monitor developments related to Section 232 copper requirements and will provide updates as they become available. If you have questions about the guidance, the new ACE reporting requirements, or obligations under Proclamation 11021, please contact your Husch Blackwell attorney.
Recent Comments