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9903.81.92 (Ended): Section 232 Steel Derivative U.S.-Melt Exemption

Published: October 21, 2026  ·  8 min read

Key Points

On this page

  1. What HTS 9903.81.92 was and what it covered
  2. The zero-duty structure: an exemption, not a duty rate
  3. How 9903.81.92 sat alongside companion Section 232 derivative headings
  4. How the heading appeared on a customs entry
  5. Consolidation under Proclamation 11021 and the end of this heading
  6. Refund and correction posture after the heading ended
  7. What importers should do
  8. Key references

HTS 9903.81.92 was a Chapter 99 exemption heading under the Section 232 steel derivatives program. It applied to derivative iron or steel products, in the tariff subheadings listed in note 16 subdivisions (m), (n), (t), or (u) to Chapter 99, where those derivative products were processed in another country from steel articles that were melted and poured in the United States. The heading carried a zero percent additional duty. It ended on April 6, 2026, and is no longer in force. As of October 21, 2026, entries may no longer claim it. The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source.

What HTS 9903.81.92 was and what it covered

The official heading text read: Derivative iron or steel products provided for in the tariff subheadings enumerated in subdivisions (m), (n), (t) or (u) of note 16 to this subchapter, where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States.

In plain English, this heading described finished or semi-finished derivative products that physically incorporated U.S.-origin steel, in the sense that the underlying steel was melted and poured domestically, even though the derivative product itself was manufactured or further processed abroad. The product still had to fall within one of the derivative steel subheadings enumerated in the relevant subdivisions of note 16 to Chapter 99; the heading did not apply to all steel products, only to those specifically listed there.

To confirm which subheadings were enumerated in subdivisions (m), (n), (t), and (u) of note 16, consult the Harmonized Tariff Schedule (hts.usitc.gov) as it read prior to April 6, 2026, or verify with your customs broker, since those lists governed the heading's scope.

The zero-duty structure: an exemption, not a duty rate

9903.81.92 was an exemption heading. Its zero percent rate was not a preferential tariff or a reduced column rate; it was a statement that no additional Section 232 derivative duty applied to qualifying goods. The Section 232 derivative program imposed additional duties on certain steel derivative products. This heading was the mechanism by which importers whose goods qualified, because the underlying steel was melted and poured in the United States, demonstrated that the additional duty did not apply to their shipment.

Because the heading carried no duty itself, there was never a dollar amount collected under it. The value of claiming it was entirely in what it prevented: the assessment of the companion duty heading's additional rate.

How 9903.81.92 sat alongside companion Section 232 derivative headings

Within the Section 232 steel derivatives program, multiple Chapter 99 headings governed different situations. 9903.81.90 and 9903.81.91 were the companion headings that sat beside 9903.81.92 in the same program structure. Importers whose derivative steel products did not qualify for the U.S.-melt exemption, because the underlying steel was not melted and poured in the United States, would have been subject to a duty-bearing companion heading rather than this zero-duty one.

The three headings collectively formed the Section 232 steel derivatives framework before the April 6, 2026 consolidation. The specific rates and country applicability of 9903.81.90 and 9903.81.91 are outside the scope of this article; confirm those with your broker or in the historical HTSUS. A parallel structure applied to the Section 232 copper derivatives program, as described in our article on 9903.78.02 (Ended): Copper 232 Non-Duty Split Filing Heading.

How the heading appeared on a customs entry

Like all Chapter 99 codes used in the Section 232 context, 9903.81.92 rode as a secondary tariff line on the entry summary. An importer would declare the base chapter 1-97 classification on one line, then add 9903.81.92 as an additional line for the same commercial line item. ACE entry summary processing recognized the Chapter 99 code as the relevant Section 232 program claim. For more on how ACE entry summary lines work structurally, see ES-002: ACE Reports Entry Summary Line Details Explained.

No duty was deposited against the 9903.81.92 line itself. The evidentiary burden of demonstrating that the steel was melted and poured in the United States rested with the importer, who needed documentation, typically a mill certificate or equivalent, to support the claim on request.

Consolidation under Proclamation 11021 and the end of this heading

On April 6, 2026, the Section 232 metal actions were consolidated under Proclamation 11021 (91 FR 18201). That consolidation retired the existing 9903.81 derivative steel heading series, including 9903.81.92, and moved the Section 232 steel program structure into the 9903.82 heading series. CBP provided operational implementation guidance in CSMS 68253075.

After April 6, 2026, 9903.81.92 was no longer a valid secondary tariff line for new entries. Importers and brokers filing entries for derivative steel products on or after that date needed to consult the 9903.82 series and the updated note 16 to Chapter 99 to determine the correct heading. This article does not name a specific successor heading within 9903.82 because the facts block does not carry one; confirm the applicable 9903.82 heading for your product with the current HTSUS or your broker.

For a broader view of Chapter 99 code changes in 2026, see 2026 tariff code overview.

Refund and correction posture after the heading ended

Because 9903.81.92 carried no duty itself, its end on April 6, 2026 created nothing to refund under it directly. There is no refund process tied to the expiration of an exemption heading.

However, if an importer paid Section 232 additional duty under a companion duty-bearing heading, such as 9903.81.90 or 9903.81.91, on an entry where 9903.81.92 should have been claimed but was not, that importer may follow the ordinary post summary correction or protest path for that entry. The specific steps depend on the entry's liquidation status; a post summary correction is available before liquidation and a protest is the vehicle after liquidation. Check cbp.gov for current procedural guidance on both mechanisms.

Two important limitations apply to any such correction effort:

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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