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Dear Friends and Customers,
 
We have noticed an increased number of CBP audits for steel and aluminum products imported into the U.S.A.  For steel or aluminum imports under section 232, we would like to provide clarification on what determines the country of origin under Presidential Proclamation 232

What CBP is looking for on Section 232 issues,  is a certificate(s) from the importer from the “original” melting facility which states where that material came from (was it raw material or scrap material?). In the end, it is where the steel or aluminum was originally “melted”,  what will determine its’ country of origin.
 
CBP has explained to us, that sometime importers purchase this material from other parties who only further manufactured that steel or aluminum item but, did not originally melt it. Just a testing certificate from a third party is not going to tell CBP who really “melted” this original product which may be sold to another domestic or foreign manufacturer who processed that original material into say steel beams or something.
 
When AD/CVD issues are at play too, this also becomes very important to the US Department of Commerce as well. Because, where the original steel or aluminum was produced (melted and made into steel product for further usage/further manufacturing or aluminum material for further usage/further manufacturing) is where the AD/CVD case can be/will be based (under their guidelines).
 
This is where CBP has seen multiple issues-importers providing information only from where the final manufacturing took place. At times for AD/CVD this does matter but other times it is where the original steel or aluminum was made that matters more (depending on the AD/CVD case).
 
Conclusion:  
 
For Presidential Section 232 , CBP needs to know where the steel or aluminum was originally melted (what country). Not, where that material was tested by the importer for quality or other industrial purposes and not where the final steel or aluminum product was completed.