Section 232 Castings HTS 2026: Your Complete Buyer's Guide
You found a foundry in Qingdao that can pour SG iron castings 35% cheaper than your current supplier. The quote looks great. Then your freight forwarder sends you the customs estimate, and suddenly your 35% saving turns into a 5% loss.
That's the Section 232 derivative tariff effect on castings. It's been hitting buyers since 2020, and it's still here in 2026. But the details that matter — which HTS codes, what rate, how to legally avoid it — keep shifting. Most articles on this topic give you wrong numbers or outdated advice. This guide gives you the actual 2026 rates, the exact HTS codes, and a sourcing playbook that survives customs review.
What Exactly Is the Section 232 Derivative List, and Does It Cover Castings?
Section 232 of the Trade Expansion Act of 1962 lets the US government slap tariffs on imports that threaten national security. In 2018, that meant 25% on steel and 10% on aluminum. But smart importers quickly found a workaround: ship the finished product instead of the raw material. A steel valve body, for example, isn't a steel coil — so some importers argued it dodged the tariff.
Customs disagreed. In early 2020, the Commerce Department issued derivative determinations that extended Section 232 duties to downstream products made from steel and aluminum — including castings. If the article is "cast" and made of ferrous metal or aluminum, it's on the list.
Which Castings Are Covered?
- Iron and steel castings — Chapter 73, headings 7325 (cast articles of iron/steel) and 7326 (forged but with cast subheadings in practice). This includes gray iron, ductile iron, malleable iron, and steel sand castings.
- Aluminum castings — Chapter 76, primarily heading 7616, including die cast, permanent mold, and sand cast aluminum parts.
- Cast fittings and flanges — Chapter 73, classified under 7307 if they're pipe fittings, even when they start life as castings.
When you file your entry, you'll need to report the Section 232 duty using a special Chapter 99 HTS code:
| Product | Base HTS (typical) | Section 232 Chapter 99 Code | Additional Duty |
|---|---|---|---|
| Cast iron articles (gray/ductile/malleable) | 7325.10.00 | 9903.80.15 | 25% |
| Cast steel articles | 7325.99.10 | 9903.80.15 | 25% |
| Cast aluminum articles | 7616.99.51 | 9903.85.01 | 10% |
Key correction: Some sources still claim the derivative duty on castings is 50%. It's not. Steel castings pay 25%, aluminum castings pay 10%. Get this wrong and you'll budget incorrectly on every PO you place.
The Real 2026 Rates: What You'll Actually Pay (Stacked)
The Section 232 derivative duty never works alone. It stacks on top of your base MFN rate. And if you're sourcing from China, Section 301 duties stack on top of that too. Here's the 2026 math that matters:
Steel Castings From China
| Component | Rate |
|---|---|
| MFN base rate (typical 7325) | 2.9% |
| Section 232 derivative | 25% |
| Section 301 List 4A | 25% |
| Total effective duty | ≈ 52.9% |
Aluminum Castings From China
| Component | Rate |
|---|---|
| MFN base rate (typical 7616) | 2.6% |
| Section 232 derivative | 10% |
| Section 301 List 3/4A | 25% |
| Total effective duty | ≈ 37.6% |
That's before you factor in anti-dumping and countervailing duty cases. Certain Chinese foundries are already hit with AD/CVD orders on specific products. In 2026, you should always ask your customs broker whether your specific HTS code has an active AD/CVD case. It can add another 40-200% in extreme cases.
How to Avoid Section 232 on Castings (Legally, in 2026)
The most common misconception in 2026 is that you can still apply for a Section 232 exclusion. You can't. The general exclusion process ended. It's not "largely closed" — it's closed for practical purposes. Some importers still file, and some applications sit in limbo for years. Don't build your sourcing strategy on an exclusion that will never come.
Workable Strategies in 2026
1. Source from USMCA Countries (Mexico / Canada)
This is the cleanest legal path. Castings from Mexico or Canada that meet USMCA rules of origin are exempt from Section 232 derivative duties entirely. You still pay the MFN rate (usually around 2-4% for castings), but you skip the 25% or 10% additional duty.
The catch: Mexico's foundry industry is smaller than you might think, and their casting capacity for complex parts is limited. For many buyers, the solution is relocating secondary operations — have the casting rough-made in Asia, then machine it in Mexico so it qualifies for USMCA. That's a bigger investment than just changing suppliers, but for high-volume SKUs, the duty savings justify it.
Read our full Mexico casting sourcing guide2. Verify Your HTS Classification (Don't Assume)
You'd be surprised how many importers pay 25% Section 232 duty on products that shouldn't be classified under the derivative list at all. Or the opposite — they skip the duty on a product that's actually covered, which gets them a customs penalty notice and a bill for back duties with interest.
A few classification traps we see constantly:
- Machined vs. unmachined: Heavy machining can change the classification from "cast article" to a more specific product under another heading. The rule is complex and depends on whether the part has "the essential character" of a cast article. Get a ruling if you're close to the line.
- Aggregations: If a casting is imported as part of a larger assembly, the Section 232 duty applies only to the value of the casting component — unless it's already "commingled" and pays on the full value. Customs looks at how your invoice describes the goods.
- Tooling shipped with castings: The tooling value might be hit with Section 232 if it's classified as steel articles. Separate it on the invoice with a distinct HTS code.
3. Use a Customs Broker Who Knows Castings
This sounds like generic advice. It's not. Most brokers process steel and aluminum derivative entries every day. But castings have quirks: Chapter 73 heading 7325 is a "basket" heading with lots of gray area. A broker who regularly handles cast pipe fittings, valve bodies, and pump housings will catch issues that a generic entry writer won't.
Ask your broker three questions before choosing them:
- "How many Section 232 derivative entries for castings did you handle last quarter?"
- "Can you show me a recent 9903.80.15 entry summary?"
- "Who in your office owns the Chapter 99 code updates?"
If they hesitate on any of these, move on.
4. Negotiate with Foundries on Delivered Duty Paid (DDP) Terms
When you buy DDP, the supplier is responsible for customs clearance and duties. But most Chinese foundries don't price DDP accurately for Section 232 goods — they under-quote, fail at customs, and then hit you with a "duty adjustment" invoice. If you do DDP, get a written commitment that the quoted price includes all Section 232 and Section 301 duties, with no post-entry adjustments. Some suppliers will walk away. The ones who stay are the ones you can actually trust.
The Four Costly Mistakes Buyers Make With Section 232 Castings
Mistake 1: Trusting the 50% Figure
We've seen pricing models from three different sourcing agents that use a 50% Section 232 tariff on castings. It's wrong. Steel castings face 25%. Aluminum castings face 10%. The confusion probably comes from the 2018 steel tariff being 25% plus an additional 25% Section 301 for China-origin goods — people added them incorrectly. But this mistake can cost you at the budgeting stage: you'll build in too much duty, inflate your pricing, and lose the bid to a competitor who did the actual math.
Mistake 2: Assuming India and Vietnam Are Safe Havens
India and Vietnam are not subject to Section 232, so you'd think they're clean. And they are — on Section 232. But they also get hit with AD/CVD cases as the US shifts against more countries. In 2024-2025, the Commerce Department opened new anti-dumping investigations on aluminum castings from multiple countries. That trend hasn't stopped in 2026. Vietnam is increasingly under AD/CVD scrutiny for aluminum products, and India faces ongoing cases on iron castings.
The takeaway: no country is "safe" for castings in 2026. You need to check the duty picture for your specific HTS code each quarter, not just when you first set up the supply chain.
Mistake 3: Trying to Dodge the Duty With Origin "Workarounds"
Here's a classic scenario: Your Chinese foundry ships castings to Vietnam, does light finishing (drilling holes, powder coating), and ships to the US claiming "Made in Vietnam" to avoid Section 232. This is substantial transformation fraud. It fails customs audits, gets your goods seized, and lands your company on Customs' blacklist. CBP in 2026 is more aggressive than ever about enforcing Section 232 origin because they know these workarounds exist.
Legal origin requires the casting to be actually manufactured (melted, poured, and finished) in the claimed origin country. Finishing operations don't count. Don't risk your entire supply chain on this one.
Mistake 4: Ignoring the Chapter 99 Update Cycle
HTS codes and Chapter 99 notes change. In 2025, CBP updated the list of which derivative products require 9903.80.15 vs. other new codes. Some buyers who assumed their castings were under 9903.80.15 discovered they needed a different Chapter 99 code — or none at all — depending on the specific product. And for certain stainless steel castings, the rules differ. Never assume your 2024 classification is still correct in 2026. Get a reclassification check at least once a year.
Cost Breakdown: What a $100,000 Casting Order Actually Costs in Duties
Let's make this concrete. Here's a $100,000 (FOB) steel casting order from a Chinese foundry, and from an equivalent order in Mexico:
| China Sourcing | Mexico Sourcing | |
|---|---|---|
| FOB value | $100,000 | $100,000 |
| Freight & insurance | $4,500 | $1,800 |
| MFN duty (2.9%) | $2,900 | $2,900 |
| Section 232 derivative (25%) | $25,000 | $0 |
| Section 301 (25%) | $25,000 | $0 |
| Total landed cost | $157,400 | $104,700 |
The Mexico route saves $52,700 on a single $100K order. Even if Mexican foundry prices run 15-20% higher per piece, the duty savings usually override the per-unit cost difference. That's why USMCA sourcing is the 2026 play.
How to Negotiate with a Foundry in 2026
Once you've figured out your duty strategy, the negotiation conversation shifts. Here's what we tell buyers:
- Ask for the casting weight and material grade in the quote. Duty is calculated on transaction value, but Section 232 derivative rates sometimes get challenged based on weight. Accurate weight data protects you in a customs audit.
- Request CKD/SKD shipping options. If you're importing castings as part of a pump or valve assembly, you might shift the classification to a more favorable heading. This requires careful engineering plus broker input — but it can cut your effective duty rate dramatically.
- Push for MOQ-based tiered pricing that absorbs duty. Some foundries with US subsidiaries or warehouses in Canada can restructure the transaction to reduce the duty impact. Not all can. But the ones who understand Section 232 are worth partnering with.
The Country-by-Country Check (2026)
| Source Country | Section 232 | Section 301 | AD/CVD Risk | Total Effective Duty (Steel) | Verdict |
|---|---|---|---|---|---|
| China | 25% | 25% | High | ≈ 52.9% | Only for unique capability |
| India | 0% | 0% | Medium | ≈ 2.9% | Good cost, look for AD cases |
| Vietnam | 0% | 0% | Rising | ≈ 2.9% | Promising but monitor |
| Turkey | 0% | 0% | Low | ≈ 2.9% | Good for valve castings |
| Mexico | 0% (USMCA) | 0% | Low | ≈ 2.9% | Best for high volume |
| Canada | 0% (USMCA) | 0% | Low | ≈ 2.9% | Good but capacity limited |
FAQ
What exactly is the Section 232 derivative list?
The derivative list is the Commerce Department's expansion of steel and aluminum tariffs to downstream products. It covers products made from steel or aluminum that they consider sensitive enough to include. Castings are on the list because they're the most common intermediate form of metal manufacturing.
Are all castings subject to the 25% or 10% duty?
No. The rate depends on the metal (steel vs. aluminum) and on the specific product classification. Some castings fall under different HTS headings that aren't on the derivative list. Also, imports from USMCA countries are exempt. Ceramic molds and investment-cast parts sometimes get classified differently. Always verify with a customs broker.
How do I find the right Chapter 99 code for my casting?
Start with CBP's online HTS tool (hts.usitc.gov). Enter your base HTS code like 7325.99.10, and it will show the applicable Chapter 99 codes. Then confirm with your broker — this is not a DIY task for high-value shipments.
Is NAFTA or USMCA still the workaround in 2026?
Yes — if your product qualifies under USMCA rules of origin. That means the casting must be produced (melted, poured, and materially processed) in a USMCA country. Simply shipping from China to Mexico and relabeling doesn't qualify. For genuinely Mexican-made castings, it's the cleanest Section 232 exemption available.
Can I pass the Section 232 cost to my customers?
That's a commercial decision, but in a competitive market, your competitors are also paying the same duty. The buyer who sources from a lower-duty country can often undercut you by 10-20% on landed cost. So while you can pass it on, you'll lose deals. The better play is to structure your supply chain to reduce the duty.
Your Next Steps (Do These Before Your Next PO)
- Get your castings reclassified. Send your current HTS codes to a customs broker and ask for a Section 232 derivative compliance check. Do this before you place your next order, because retroactive duty bills are a real risk.
- Run a multi-country landed cost model. Don't just compare unit prices — model the full duty stack for each source country. Include freight, duties, and potential AD/CVD exposure.
- Investigate USMCA foundry options. If you have high-volume castings, the Mexico route is likely your strongest play. It might mean retooling some specifications, but the duty savings can pay for that within a year.
If you don't have a broker who's fluent in Section 232 derivatives, work with our customs compliance team to do a free tariff audit of your castings import.
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