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Responding to Section 232 Steel and Aluminum Declaration Requests

A step-by-step process for suppliers asked to complete a Section 232 declaration: confirm metal content, trace melt, pour, smelt, and cast countries, and fill in the form.

This guide reflects the declaration process as of 2025. Tariff rules change frequently—confirm current requirements before responding.

If a customer has asked you to complete a Section 232 steel and aluminum declaration for one of your parts, the process below will help you respond. The same process will also work for future Section 232 requests.

Step 1: Does the Part Contain Steel, Aluminum, or Both?

First, determine whether the part in question contains any steel, any aluminum, or both. The answer determines what documentation you need to ask for in the next steps.

Step 2: Find Out Where the Metal Is From

Ask purchasing

Once you know whether the part contains steel or aluminum, reach out to your purchasing team and ask for documentation. Specifically:

  • If the part contains any steel: ask for mill test certificates, or any other documentation, showing the country of melt (where the raw steel was first produced in liquid form) and the country of pour (where the liquid steel was poured into solid form).
  • If the part contains any aluminum: ask for certificates of analysis, or any other documentation, showing the country of smelt (where the aluminum was produced from raw materials through the smelting process) and the country of cast (where the aluminum was formed into a solid shape).

If purchasing can’t answer, ask your suppliers

If your purchasing team does not have certificates or documentation for the steel or aluminum in the part, or simply cannot say where either metal is from, repeat the same request with the supplier of the steel or aluminum in the part.

Step 3: Complete the Customer’s Form

Once you have gathered the information from Steps 1 and 2, complete the customer’s request as follows.

Executive orders and proclamations

If the part contains any steel or aluminum, the answer is Yes: it is subject to the executive orders and proclamations. The current proclamations apply tariffs to steel and aluminum products.

Category selection

  • Steel only (no aluminum): select “Steel Derivative” (HTS Chapter 73 products).
  • Aluminum only (no steel): select “Aluminum Derivative” (HTS Chapter 76 products).
  • Both steel and aluminum: select “Steel and Aluminum.”

IEEPA requirements

Report the countries of melt and pour (for steel) and of smelt and cast (for aluminum). If either the steel or the aluminum originates from Russia, Belarus, or Myanmar, declare that the product is subject to IEEPA sanctions and additional restrictions.

Country of origin

Use the countries identified in the mill test certificates and certificates of analysis you gathered in Step 2.

If you find yourself fielding these requests often, see declaration tools built for suppliers, or manage declarations in MatCheck alongside your other material compliance work.