Can I still get a Section 232 exclusion?

What Section 232 is

Section 232 of the Trade Expansion Act of 1962 (19 USC 1862) allows the President to impose tariffs or quotas on imports deemed a threat to national security. The 2018 Section 232 tariffs imposed:

• 25 percent tariff on steel imports
• 10 percent tariff on aluminum imports

These rates have since evolved with country-specific quotas, TRQs (tariff-rate quotas), and exclusion programs. The 2025 Trump administration revived and expanded Section 232 tariffs on steel, aluminum, and related derivative products.

The exclusion program history

From 2018 through February 10, 2025, the Department of Commerce Bureau of Industry and Security (BIS) accepted exclusion requests. An approved exclusion let an importer bring in specific steel or aluminum products free of the 232 tariff, typically for one year.

Presidential Proclamation 10896 (signed February 10, 2025) terminated the exclusion program. The stated rationale was that the exclusion regime had expanded beyond national security intent and was undercutting domestic steel and aluminum producers.

Timeline:

• March 2018 — Section 232 tariffs imposed
• 2018-2024 — BIS exclusion program active, ~500,000+ requests processed
• February 10, 2025 — Exclusion program terminated, no new requests accepted
• April 2026 — Existing approved exclusions still honored until expiry; no renewals

What remains valid

If you hold an approved exclusion with a valid expiration date, CBP will honor it until expiry. Check the USITC Section 232 Exclusions Database for your specific exclusion reference number and expiration.

After your current exclusion expires, you pay the full 232 duty. There is no renewal pathway.

Alternatives to Section 232 exclusions

Without the exclusion program, importers have narrower but still useful mitigation tools:

• Country-specific agreements — Some countries (UK, EU, Japan) have negotiated quota or TRQ arrangements that reduce 232 exposure. Check the current proclamation text for applicable country terms.
• Product substitution — Shift sourcing to a non-232 origin or non-steel material where feasible
• Tariff engineering — Verify classification; some products at the margin of 232 coverage may classify outside the scope. See tariff engineering
• Drawback — If goods are exported or destroyed, 232 duty can be recovered at 99 percent under 19 USC 1313
• FTZ strategy — Admitting goods to a Foreign Trade Zone can defer duty, and structured FTZ operations may alter the duty calculation on eventual withdrawal

Section 232 and CAPE IEEPA refunds

Section 232 duties are not part of the CAPE IEEPA refund pool. The February 20, 2026 Supreme Court ruling struck down IEEPA-based tariffs only. Section 232 duties remain fully in force.

When you pull your entry data, break out each duty type on the 7501:

• MFN duty (keep)
• Section 232 duty (keep)
• Section 301 duty (keep, see Section 301 refund)
• IEEPA duty (refundable via CAPE)

Only the IEEPA line flows to CAPE. Do not include 232 duty in your refund claim; CBP's automated matching will reject claims that include ineligible duty types.

Challenging Section 232 classifications

If you believe your product is misclassified under a 232-covered HTS subheading, you can:

1. File a Post-Summary Correction under 19 CFR 149 within 300 days of entry
2. File a CF-19 protest within 180 days of liquidation per 19 USC 1514
3. Request a binding ruling under 19 CFR 177 for future entries

These are classification challenges, not exclusion requests. They apply whether or not the 232 program is accepting new exclusions.

Court challenges to Section 232

Unlike IEEPA, Section 232 has survived constitutional challenges. American Institute for International Steel v. United States (Fed. Cir. 2020) upheld the statute against a non-delegation challenge. Section 232 is settled law and is not expected to be struck down.

This means 232 duty recovery happens only through drawback, classification correction, or exclusion — and the exclusion door is now closed for new requests.

Calculate your tariff refund → /calculators/ieepa-refund

Related questions

Are Section 301 tariffs refundable? No. See Section 301 refund.

Can I combine drawback with Section 232? Yes, 1313 drawback applies to 232 duty on exports.

What's the CAPE refund window? 180 days from liquidation for CF-19 protests. See CAPE eligibility.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.