Section 232 at 50%: the documents US buyers of steel strapping seals and buckles need

Within four months, the US tariff on imported steel moved twice. Proclamation 10896, signed on 10 February 2025, applied a 25% Section 232 duty to steel articles and listed derivative articles from all countries from 12 March 2025, ending the country arrangements, the general approved exclusions and the product exclusion process. Proclamation 10947, signed on 3 June 2025, raised the rate to 50% from 12:01 a.m. EDT on 4 June 2025. Articles of the United Kingdom remained at 25%, with the possibility of adjustment on or after 9 July 2025 under the US–UK Economic Prosperity Deal.

For buyers of steel strap and steel closures, the rate is only part of the change. Both proclamations, and the customs guidance between them, put weight on documentation: where the steel was melted and poured, and how much of an article is steel.

The sequence in one table

Date	Measure	What it meant for strapping buyers
21 November 2024	Melt-and-pour reporting begins for certain steel articles	The first step towards tracing steel sources at entry
7 March 2025	CBP guidance: melt-and-pour country mandatory for steel and derivatives	Suppliers must trace the steel source for each line
12 March 2025	25% for all countries; country arrangements and exclusions end	Former arrangements for partners such as the EU, UK, Canada and Mexico no longer applied
4 June 2025	50% for steel articles and derivatives; UK at 25%	Higher landed cost and closer scrutiny of content declarations
9 July 2025	Earliest date for adjusting the UK arrangement	UK-origin pricing may need another review

Which strapping items are in scope

Section 232 covers steel articles and the derivative articles listed in the annexes. Steel strap is normally classified as a flat-rolled steel product, and flat-rolled products fall within the HTS ranges that defined steel articles in Proclamation 9705 of March 2018. Seals, buckles and clips are fabricated items: whether a particular one is covered depends on its HTSUS code and whether that code appears among the listed derivatives. In ruling N079342 of October 2009, for example, CBP classified a galvanized steel push-type strapping seal under subheading 8309.90.00, seals and other packing accessories of base metal, outside the steel chapters. That decision belongs with the importer and its customs broker, made on the actual product and its description.

Proclamation 10947 also changed how the duty is measured. It applies the additional duty only to the steel content of articles in Chapter 73, while the non-steel content falls under the reciprocal tariffs of Executive Order 14257. Proclamation 10896 had already applied the steel-content basis to listed derivatives outside Chapter 73. For a galvanized steel seal or wire buckle, most of the article is steel, but the declared steel content must still be accurate and documented in line with CBP’s declaration requirements; an estimate is not enough.

Melt and pour: tracing the steel

In CSMS 64348411 of 7 March 2025, US Customs and Border Protection stated that reporting the country where steel was melted and poured is mandatory for steel and steel derivatives. An earlier bulletin, CSMS 62582900 of October 2024, describes the country of melt and pour as the original location where raw steel is first produced in liquid form in a steelmaking furnace and then poured into its first solid shape.

A component maker receives its steel as wire rod, wire or strip from a mill or processor. The melt-and-pour country belongs to that upstream steel, not to the factory that forms the buckle or presses the seal. Ask suppliers early, because reconstructing the chain after shipment is slow. Useful evidence includes:

• the mill test certificate, or an equivalent document for the steel input, showing the melt location;
• a traceable link between that document and the production lot of the components;
• the supplier’s written declaration of the melt-and-pour country for each line on the invoice.

Steel content declarations

Proclamation 10947 directs CBP to issue guidance mandating strict compliance with steel content declarations, and states that importers who underreport may face significant monetary penalties, loss of import privileges and criminal liability. A supplier’s casual estimate is therefore not good enough.

Agree with your broker which data the supplier must provide, then write it into the purchase order. For steel closures this will usually mean the steel weight per piece and per carton, the basis used for the steel value and the treatment of coatings or any non-steel parts. Ask for these figures on the commercial invoice or on a signed annex, line by line, so the broker can match them to the entry.

Contract and quotation points

• Duty basis. State whether prices include or exclude US duties. A DDP price fixed before 4 June 2025 may no longer cover the duty.
• Origin and melt country. Both, for every line.
• Weights. Net and gross per carton, and steel weight per piece where required.
• No drawback. Proclamation 10947 states that drawback is not available on these duties, so re-export plans should not count on a refund.
• Change clause. Agree how price and documents will be handled if the rate or the derivative list changes again.

Treat the documentation as part of the product. An order that arrives with complete melt-and-pour and steel content data clears with fewer questions than an identical order that arrives without it.

Keep the order description precise

Accurate item data makes every customs step easier. The steel strapping seal, galvanized wire buckle and phosphated wire buckle pages list nominal strap width, wire or sheet details and finish for each family. Use the enquiry page to set out the destination, the documents your broker requires and the quantities; origin and steel-source documentation is discussed for each enquiry.