9903.82.16 Consolidated Metal 232: Russian Copper and Derivative Steel

Key Points

• HTS code 9903.82.16 imposes a 25 percent additional duty on articles of copper and derivative steel that are the product of the Russian Federation, effective 2026-04-06.
• The code covers goods described in subdivisions (c)(vii), (c)(viii), and (c)(xi) of U.S. Note 16 to Chapter 99 of the HTSUS; confirm exact product scope against those note subdivisions before filing.
• 9903.82.16 rides alongside the regular Chapter 1-97 classification on each entry line, just as other Chapter 99 Section 232 codes do.
• Country of origin determines applicability; transshipment through a third country does not eliminate the duty if Russia remains the country of origin.
• As of August 2026, no exclusion process or quota alternative is described in the facts available; confirm with CBP or the current HTSUS whether any exclusions have been granted for this heading.

On this page

1. What 9903.82.16 covers
2. The 25 percent rate and its effective date
3. Product scope: U.S. Note 16 subdivisions (c)(vii), (c)(viii), and (c)(xi)
4. How 9903.82.16 stacks with other duties
5. Country of origin and transshipment risk
6. How the code appears on a customs entry
7. What importers should do
8. Key references

HTS 9903.82.16 is a Section 232 consolidated metals tariff code that adds a 25 percent duty on articles of copper and derivative steel the product of the Russian Federation, effective 2026-04-06. It sits in the 9903.82 block of Chapter 99, which governs the consolidated Section 232 regime for steel, aluminum, and copper. Any importer bringing Russian-origin copper or derivative steel articles within the scope of U.S. Note 16, subdivisions (c)(vii), (c)(viii), and (c)(xi), must report this code on every affected entry line alongside the standard Chapter 1-97 classification.

The links in this article go to the primary documents: the official tariff schedule pages and government agency references themselves. Read the source.

What 9903.82.16 covers

The official heading text for 9903.82.16 reads: "Articles of copper and derivative steel the product of the Russian Federation, as provided for in subdivisions (c)(vii)-(viii) and (xi) of U.S. note 16 to this subchapter."

Two material families are addressed together under this code:

• Articles of copper: finished and semi-finished copper goods of Russian origin that fall within the specified note subdivisions.
• Derivative steel articles: goods whose value or content is substantially derived from steel and that are the product of Russia, again as defined in the same note subdivisions.

The 9903.82 block is the Chapter 99 home of the consolidated Section 232 regime that became effective 2026-04-06. For neighboring codes in this block, see the related articles on 9903.82.12, 9903.82.10, and 9903.82.11, which cover different country and product combinations within the same regime.

The 25 percent rate and its effective date

The additional duty rate under 9903.82.16 is 25 percent, applied on top of all other applicable duties. The rate took effect on 2026-04-06. There is no scheduled phase-in or phase-out date in the available facts; treat the rate as continuing until a formal Federal Register notice or HTSUS amendment states otherwise.

If you are reviewing entries filed before 2026-04-06, this code did not apply. For entries on or after that date involving Russian-origin copper or derivative steel articles in scope, the 25 percent additional duty is owed at the time of entry summary. Confirm the current schedule at the official HTSUS online.

Product scope: U.S. Note 16 subdivisions (c)(vii), (c)(viii), and (c)(xi)

The precise product boundaries for 9903.82.16 are set by U.S. Note 16 to Chapter 99 (Subchapter III), specifically subdivisions (c)(vii), (c)(viii), and (c)(xi). The note language controls which copper articles and which derivative steel articles are captured. Do not rely solely on the six-digit Chapter 1-97 HTS number to determine applicability; the note subdivisions define the scope independently.

Why the note subdivisions matter

Chapter 99 codes routinely incorporate Chapter 99 note language to define product coverage rather than listing every underlying 8-10 digit HTSUS subheading. This means two entry lines with the same base subheading could have different Chapter 99 treatment depending on the country of origin and the specific note subdivision. Review the full text of U.S. Note 16 at hts.usitc.gov to map each commodity against the correct subdivision before filing.

Derivative steel: a reminder on scope

Derivative steel articles are goods that are not themselves classified as steel under the base schedule but whose value is primarily attributable to steel content. Common examples include certain fabricated steel parts. The HTSUS note language governs; check subdivision (c)(viii) specifically for the derivative steel definition as applied here. If the applicable subdivision is silent on a specific product, confirm classification with a licensed customs broker before filing.

How 9903.82.16 stacks with other duties

The 25 percent Section 232 additional duty under 9903.82.16 is additive. It stacks on top of:

• The base column 1 general rate of duty (or the applicable column 2 rate for Russian-origin goods, which is typically much higher).
• Any applicable antidumping or countervailing duty (ADD/CVD) orders on the specific product.
• Any other Chapter 99 additional duties that may simultaneously apply.

Russia is not a most-favored-nation (MFN) trading partner for purposes of normal U.S. tariff treatment; Russian-origin goods are subject to column 2 rates under the base schedule. The 25 percent Section 232 additional duty under 9903.82.16 is imposed on top of whichever base rate applies. The combined duty burden for Russian copper and derivative steel articles can therefore be substantial. Use the duty calculator to model total landed cost across these stacking layers.

For a broader view of how 2026 Chapter 99 codes interact, see the 2026 tariff code overview.

Country of origin and transshipment risk

9903.82.16 applies to goods that are the product of the Russian Federation. Country of origin is determined under U.S. customs law, primarily through the substantial transformation test. Routing copper or derivative steel through a third country for minimal processing does not change the country of origin if Russia is where the article last underwent substantial transformation.

CBP actively scrutinizes transshipment of metals subject to Section 232 duties. Routing Russian copper through, for example, a third country for repackaging or minor finishing is unlikely to constitute substantial transformation and will not eliminate the 9903.82.16 duty. For more on how CBP detects and penalizes transshipment, see Transshipment Customs Fraud: How CBP Catches It and What It Costs. For the full framework of substantial transformation analysis, see Substantial Transformation Test: Country of Origin Explained.

Importers should obtain detailed mill certificates, production records, and supplier declarations to establish and document origin. CBP may issue a CF-28 or CF-29 request for information on origin if the declared origin appears inconsistent with the supply chain.

How the code appears on a customs entry

Like all Chapter 99 Section 232 codes, 9903.82.16 is reported as a second line on the CBP Form 7501 (or its ACE electronic equivalent) alongside the primary Chapter 1-97 classification. The entry structure is:

• Line 1: The standard 10-digit HTSUS subheading (e.g. a copper pipe fitting subheading in Chapter 74 or a derivative steel part in Chapter 73), with its applicable base rate and any ADD/CVD case number.
• Line 2: 9903.82.16, with the 25 percent additional duty calculated on the same customs value as line 1.

The Chapter 99 line does not carry its own separate quantity; it inherits the value from the Chapter 1-97 line. ACE will require both lines to be present for entries where this duty applies. Confirm the ACE filing requirements with your broker and review any relevant CBP CSMS messages for filing instructions specific to the 9903.82 block.

What importers should do

• Audit open purchase orders and shipments on or after 2026-04-06 for Russian-origin copper articles and derivative steel articles; calculate the 25 percent additional duty exposure and ensure sufficient bond coverage and cash flow.
• Read U.S. Note 16, subdivisions (c)(vii), (c)(viii), and (c)(xi) in full at hts.usitc.gov to confirm that each commodity actually falls within scope before adding 9903.82.16 to entry lines or before concluding it does not apply.
• Document country of origin thoroughly with mill certificates, production records, and supplier declarations to defend the origin determination against CBP inquiry and to assess transshipment risk.
• Check CBP's CSMS and the Federal Register at cbp.gov and federalregister.gov for any exclusions, quota provisions, or guidance notices issued after August 2026 that may affect this code.

Key references

• Harmonized Tariff Schedule of the United States (HTSUS), hts.usitc.gov: The official schedule, including Chapter 99, Subchapter III, U.S. Note 16 and the 9903.82 block. Read subdivisions (c)(vii), (c)(viii), and (c)(xi) for the product scope of 9903.82.16.
• U.S. Customs and Border Protection (CBP), cbp.gov: ACE filing guidance, CSMS messages on Section 232 entry procedures, and CF-28/CF-29 origin inquiry process.
• Federal Register, federalregister.gov: The Federal Register is the authoritative source for any proclamations, executive orders, or notices establishing or modifying the consolidated Section 232 metals regime and the 9903.82 block.
• White House, whitehouse.gov: Presidential proclamations establishing and amending Section 232 duties on steel, aluminum, and copper.
• 9903.82.12 Consolidated Metal 232: Rate, Scope, and Stacking: Related 9903.82-block code covering a different country/product combination.
• Transshipment Customs Fraud: How CBP Catches It and What It Costs: How CBP detects origin evasion in metals imports.
• Substantial Transformation Test: Country of Origin Explained: The legal standard CBP applies to determine whether processing in a third country changes origin.