On May 8, 2025, U.S. Customs and Border Protection (CBP) updated its online Frequently Asked Questions (FAQ) resource for Section 232 tariffs on steel and aluminum.
Among the questions updated was one addressing whether items that are classified under a 232 steel or aluminum tariff number, but contains no steel or aluminum, can utilize the exemption provided for in Section 3(b) of the International Economic Emergency Powers Act (IEEPA) reciprocal tariffs Executive Order. CBP's answer states "No. The phrase 'subject to Section 232 actions' implies that Section 232 duties are owed and payable. If the article does not contain any steel or aluminum that is subject to Section 232 duties, then HTS 9903.01.33 cannot be claimed. However, the IEEPA-based reciprocal duty may be applicable unless an exception applies."
The online FAQ resource can be found here:
https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel-faqs