9903.82.01 Explained: The Consolidated Metal 232 Zero-Duty Exemption

Key Points

• HTS 9903.82.01 carries a 0 percent additional duty rate; it is an exemption heading, not a duty-imposing one, within the Consolidated Metal 232 program.
• The heading covers listed articles that contain no aluminum, steel, or copper, as defined by Note 16(c) of the applicable Chapter 99 provisions.
• The effective date for this heading is 2026-04-06, coinciding with the launch of the broader Consolidated Metal 232 regime.
• Claiming this heading on an entry is a positive assertion that your product meets the Note 16(c) no-metal content test; documentation supporting that claim should be retained.
• The 9903.82.01 heading rides alongside your regular Chapter 1-97 classification line on the entry; it does not replace it.

On this page

1. What 9903.82.01 is and why it matters
2. The Consolidated Metal 232 program and the 9903.82 block
3. Product scope: the Note 16(c) no-metal test
4. Rate and effective date
5. How 9903.82.01 appears on a customs entry
6. Interaction with other tariff provisions
7. What importers should do
8. Key references

HTS 9903.82.01 is a zero-percent exemption heading inside the Consolidated Metal 232 program, effective 2026-04-06. It applies to listed articles that contain no aluminum, steel, or copper under Note 16(c), meaning importers who qualify pay no additional Section 232 metals duty on those goods. Every importer whose products fall under the 9903.82 block needs to determine whether this exemption heading, or a rate-bearing heading in the same block, applies to their merchandise.

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 9903.82.01 is and why it matters

Chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS) houses temporary and special-program duty provisions. The 9903.82 block belongs to the Consolidated Metal 232 program, which reorganized and extended Section 232 tariff coverage for steel, aluminum, and copper products. Within that block, individual headings either impose an additional duty or, like 9903.82.01, serve as an exemption or exception heading that confirms a zero-percent additional duty rate for qualifying goods.

Understanding whether 9903.82.01 or a rate-bearing sibling heading applies to your shipment is consequential. Claiming the wrong heading either overpays duty or, more seriously, underpays it and exposes the importer to penalties and a duty demand on liquidation. The heading text, confirmed in the official HTSUS at hts.usitc.gov, reads: Listed article containing no aluminum/steel/copper (note 16(c)); 0%.

The Consolidated Metal 232 program and the 9903.82 block

The Consolidated Metal 232 program, effective 2026-04-06, brought steel, aluminum, and copper Section 232 measures under a unified Chapter 99 framework in the 9903.82 block. This replaced predecessor Chapter 99 headings that terminated on the same date. The program subjects a broad range of metal-containing articles to additional duties, but it simultaneously carves out categories of goods that should not bear those duties, either because they lack the relevant metals entirely or because they fall within a defined exception.

HTS 9903.82.01 is one of those carve-outs. It exists so that importers of genuinely metal-free listed articles can classify correctly within the 9903.82 block, confirm they owe zero additional duty, and close out their entries cleanly without ambiguity about whether a metals surcharge applies.

For a broader orientation to 2026 tariff code changes, see our 2026 tariff code overview. For comparison with how exemption headings work in other Section 232 commodity programs, see our article on the 9903.79.09 Semiconductors 232 public sector exemption.

Product scope: the Note 16(c) no-metal test

The heading applies to articles that are listed within the Consolidated Metal 232 program's product coverage and that contain no aluminum, steel, or copper, as that determination is made under Note 16(c) of the relevant Chapter 99 U.S. notes.

What Note 16(c) requires

The substantive standard is embedded in Note 16(c). The facts block available as of 2026-08-17 identifies Note 16(c) as the controlling authority but does not reproduce its full text here. Importers must read Note 16(c) in the current HTSUS directly at hts.usitc.gov to confirm exactly how aluminum, steel, and copper content are measured and what thresholds, if any, apply. Do not rely on a paraphrase; read the note.

Why the no-metal determination matters

The exemption is not a blanket exclusion based on product category alone. The importer must be able to demonstrate that the specific article entering commerce satisfies the no-aluminum, no-steel, no-copper standard at the time of importation. If the product contains any of those metals, a different 9903.82 heading, potentially one carrying a positive additional duty rate, will apply instead. Confirm the applicable heading in the current HTSUS or with a licensed customs broker.

Rate and effective date

The additional duty rate under 9903.82.01 is 0 percent, effective 2026-04-06. No additional Section 232 metals duty is owed when this heading is properly claimed. The 0 percent rate is not a temporary reduction or a phase-in; it is the heading's stated rate as of 2026-08-17, reflecting the product's exemption from the metals surcharge rather than a reduced version of it.

Because the heading took effect on 2026-04-06, entries filed before that date fall under the predecessor Chapter 99 framework, which terminated on that same date. If you have entries from before 2026-04-06 that need correction or if you are evaluating refund posture on prior shipments, confirm the applicable predecessor heading and its rules directly in the HTSUS or with a broker familiar with the transition.

How 9903.82.01 appears on a customs entry

Chapter 99 headings are secondary classification lines. On a Customs and Border Protection (CBP) entry, 9903.82.01 is entered alongside the primary Chapter 1-97 HTS classification that describes what the product actually is. The Chapter 1-97 line determines the base (MFN or preferential) duty rate; the 9903.82.01 line signals that, under the Consolidated Metal 232 program, zero additional duty applies.

Both lines must appear on the entry summary. Omitting the Chapter 99 line entirely, or defaulting to a rate-bearing 9903.82 heading when 9903.82.01 is correct, creates a classification error that CBP can flag at liquidation. CBP guidance and Cargo Systems Messaging Service (CSMS) messages on Consolidated Metal 232 entry procedures are published at cbp.gov; check for any active CSMS messages that address the 9903.82 block specifically.

To model how the zero additional duty under 9903.82.01 interacts with your base duty rate and any applicable trade-preference programs, use our duty calculator.

Interaction with other tariff provisions

Claiming 9903.82.01 zeroes out the Consolidated Metal 232 additional duty but does not affect any other concurrently applicable tariff provisions. Other Chapter 99 measures, including Section 301 tariffs, reciprocal tariffs, or other commodity-specific Section 232 programs, each require their own separate Chapter 99 classification line and stack on top of the base Chapter 1-97 rate independently.

Specifically:

• A product correctly claimed under 9903.82.01 may still owe Section 301 duties if the goods originate from a covered country under that program.
• Duty drawback eligibility and restrictions on other Chapter 99 duties are governed by rules specific to each program. For context on drawback limitations in adjacent programs, see our article on CBP blocks on drawback for certain Section 301 duties.
• Country of origin determines which base rate and which preference programs apply; it does not by itself determine whether 9903.82.01 or a rate-bearing 9903.82 sibling heading applies. The determining factor for this heading is product content under Note 16(c).

If you import articles that contain some metal content, review the other headings in the 9903.82 block in the current HTSUS to identify the correct rate-bearing heading. Confirm any stacking questions with a licensed customs broker.

What importers should do

• Read Note 16(c) of the Chapter 99 U.S. notes in the current HTSUS at hts.usitc.gov and confirm that each article you intend to classify under 9903.82.01 genuinely contains no aluminum, steel, or copper by that standard.
• Retain supplier documentation, material certifications, or bill-of-materials records that support the no-metal-content determination for each product, since CBP may request substantiation on audit or at liquidation.
• Check cbp.gov for active CSMS messages addressing Consolidated Metal 232 entry procedures and any guidance specific to the 9903.82 block effective 2026-04-06.
• If entries filed before 2026-04-06 are under review, confirm the applicable predecessor heading directly in the HTSUS or with a broker rather than assuming the current 9903.82.01 framework applies retroactively.

Key references

• HTSUS, hts.usitc.gov - Official harmonized tariff schedule; current text of heading 9903.82.01 and Note 16(c).
• U.S. Customs and Border Protection, cbp.gov - CBP entry guidance and CSMS messages on Consolidated Metal 232 classification and entry procedures.
• Federal Register, federalregister.gov - Federal Register notices implementing and amending the Consolidated Metal 232 program.
• White House, whitehouse.gov - Presidential proclamations authorizing Section 232 measures underlying the Consolidated Metal 232 program.
• CustomsGenius: 2026 Tariff Code Overview - Summary of major Chapter 99 changes taking effect in 2026.
• CustomsGenius: 9903.79.09 Semiconductors 232 Public Sector Exemption Explained - Parallel analysis of how a zero-rate exemption heading works in another Section 232 program.