U.S. Customs and Border Protection has issued CSMS #69252300, establishing new country-of-smelt and country-of-cast reporting requirements for certain copper articles imported into the United States.
Beginning July 30, 2026, importers of covered copper articles from all countries of origin other than the United States must report the primary country of smelt and country of cast on the applicable entry-summary line in the Automated Commercial Environment. Importers may also report a secondary country of smelt.
The requirement stems from Presidential Proclamation 11021, which directed importers to provide CBP with information identifying where the copper used in covered imported articles was smelted and where the articles were cast. The proclamation also directed CBP to implement the reporting requirements as soon as practicable.
CBP deployed the new functionality to the ACE certification environment on July 16, 2026. The functionality will be available in the ACE production environment beginning July 30, 2026, when reporting becomes effective.
Who Is Affected?
The new reporting requirements apply to imports from all countries of origin other than the United States that are entered under the following HTSUS classifications:
- 8544.42.10
- 8544.42.20
- 8544.42.90
- 8544.49.10
Importers should not assume that every copper or copper-containing product is currently subject to the new reporting requirement. Product classification should be reviewed carefully to determine whether an imported article falls under one of the four affected HTSUS provisions.
Companies importing covered wire, cable, insulated electrical conductors, or other merchandise potentially classified under these provisions should immediately confirm whether the required smelt and cast information is available from their suppliers.
New Data Elements Required
For each covered entry-summary line, importers must report:
| Data element | Reporting status |
|---|---|
| Primary country of smelt | Required |
| Country of cast | Required |
| Secondary country of smelt | Optional; may be reported where applicable |
CBP has stated that importers may report “OTH” — Other when the primary country of smelt, secondary country of smelt, or country of cast is unknown.
Although “OTH” is an available reporting option, importers should establish a documented process for requesting the information from suppliers and retaining records supporting the data reported to CBP.
ACE Filing Requirements
The smelt and cast information will be transmitted using the new Importer’s Additional Declaration Type Code 12 — Copper Smelt and Cast Country Detail. Technical filing instructions are contained in the ACE CATAIR Entry Summary Create/Update, Version 109.
CBP also updated the ACE CATAIR Entry Summary Error Dictionary, Version 51, with new validations for copper smelt and cast reporting. Error codes 869 through 873 address missing or invalid primary-smelt, secondary-smelt, and cast country information. Entries may therefore generate an ACE error when required information is omitted or an unrecognized country code is transmitted.
Importers should coordinate with their customs brokers and internal systems teams to confirm that the required data can be collected, transmitted, and retained before the production implementation date.
Immediate Actions Recommended
Importers should take the following steps before July 30:
- Confirm product classifications. Review active products, purchase orders, and upcoming shipments to identify merchandise entered under the four affected HTSUS classifications.
- Begin supplier outreach. Request documentation identifying the primary country of smelt, country of cast, and any applicable secondary country of smelt.
- Update product and supplier records. Establish a reliable method for associating smelt and cast information with each affected SKU, part number, supplier, or manufacturing location.
- Coordinate with customs brokers. Confirm that brokers have received the required information and are prepared to transmit Declaration Type Code 12 in ACE.
- Test systems and filing processes. Where appropriate, use the ACE certification environment to confirm that data mapping and entry-summary transmissions function as expected.
- Establish recordkeeping procedures. Retain supplier certifications, mill information, production records, correspondence, and other documentation supporting the reported countries.
- Create an “OTH” review process. Define when “OTH” may be used, who must approve its use, and what supplier outreach or supporting documentation should be maintained.
Key Effective Dates
| Milestone | Date |
|---|---|
| ACE certification environment functionality available | July 16, 2026 |
| ACE production functionality available | July 30, 2026 |
| Reporting requirements become effective | July 30, 2026 |
How Buckland Can Help
Buckland’s Trade Compliance team is assisting clients with:
- HTSUS classification and applicability reviews
- Supplier smelt and cast data-collection strategies
- ACE reporting and data-element requirements
- Section 232 compliance assessments
- Entry filing and customs broker coordination
- Supporting-document and recordkeeping procedures
- Review of upcoming shipments and implementation readiness
If your company imports products under the affected tariff classifications, we recommend beginning supplier outreach immediately to ensure that the required information is available before the July 30 implementation date.
Please contact your Buckland representative for assistance evaluating your products, collecting required supplier information, or preparing your entry-filing process.
Buckland Global Trade Services will continue to monitor CBP guidance, ACE CATAIR updates, and any future changes to the affected tariff classifications or reporting requirements.
Official Resources
CBP CSMS #69252300 — Section 232 Copper Smelt and Cast Reporting Requirements
Presidential Proclamation 11021 and Federal Register Notice, 91 FR 18201
CBP CSMS #68253075 — Section 232 Duties on Imports of Aluminum, Steel, and Copper