9903.82.20 Consolidated Metal 232: USMCA Derivative Steel, 25% Duty

Key Points

• 9903.82.20 imposes a 25 percent additional duty on USMCA-origin (Canada and Mexico) derivative steel articles in which non-U.S. steel content exceeds 40 percent, effective 2026-06-08 through 2028-01-01.
• The code applies exclusively to derivative steel articles classified under U.S. note 16(c)(xi) of Chapter 99; goods belonging to note 16(c)(ix) or (c)(x) categories are not within scope of this heading.
• A significant subset of product subheadings initially armed under 9903.82.20 were parked as of August 2026 after a reconciliation determined their assignment was never lawful; those goods revert to the 9903.82.10 floor tier.
• 9903.82.20 is always filed as a two-line Chapter 99 addition alongside your regular Chapter 1-97 classification and the companion code 9903.82.21, per the official heading structure.
• The announced termination date is 2028-01-01; confirm current HTSUS text and any intervening modifications with CBP or a licensed broker before filing.

On this page

1. What 9903.82.20 is and who must care
2. Product and country scope: what qualifies under note 16(c)(xi)
3. The 25 percent rate and its effective window
4. The parked subheadings: scope reconciliation as of August 2026
5. How 9903.82.20 appears on an entry and stacks with other duties
6. What importers should do
7. Key references

As of August 2026, HTS code 9903.82.20 is the Consolidated Section 232 heading that adds a 25 percent additional duty to USMCA-qualifying derivative steel articles imported from Canada or Mexico where the non-U.S. steel content exceeds 40 percent of total steel content. It is part of the 9903.82 block of the Consolidated Metal 232 regime and is always paired with the companion code 9903.82.21 on the same entry. If your goods are derivative steel articles of Canadian or Mexican origin and your steel content mix crosses the 40 percent non-U.S. threshold, this is the heading that governs your additional duty exposure. The links throughout this article go to the primary documents: the official tariff schedule and agency reference pages themselves. Read the source.

What 9903.82.20 is and who must care

The Consolidated Metal 232 program reorganized Section 232 duties on steel, aluminum, and copper derivative articles into the 9903.82 block of Chapter 99. Within that block, the .20/.21 heading pair is specifically scoped to USMCA-partner derivative steel, meaning articles from Canada (CA) or Mexico (MX) that qualify under USMCA but whose steel content does not meet the higher U.S.-origin threshold.

The official heading text reads: CA/MX USMCA deriv steel: non-US content + US content >40%; 25%; two-line with .21. In plain English: if more than 40 percent of the steel in your article is non-U.S. origin, this 25 percent surcharge applies on top of whatever regular column 1 duty you already owe.

Importers most directly affected are those bringing in steel-containing manufactured goods, heavy equipment, vehicles, and agricultural machinery from Canadian or Mexican suppliers, particularly where the upstream steel supply chain includes non-U.S. mills. Customs brokers filing entries for these goods must include 9903.82.20 and 9903.82.21 as the Chapter 99 overlay lines.

For context on related headings within the same program, see our articles on 9903.82.18 (steel exemption heading) and 9903.82.17 (Russian derivative steel).

Product and country scope: what qualifies under note 16(c)(xi)

The 9903.82.20/.21 heading pair applies only to derivative steel articles that fall within U.S. note 16(c)(xi) of Chapter 99 (as printed in note 16(j)). This is not a general derivative steel provision. It targets a specific, enumerated list of article subheadings that were designated as (c)(xi) derivative steel products.

Country scope is limited to Canada and Mexico. Goods from all other countries are outside the reach of this particular heading. USMCA qualification is a prerequisite; if a good from Canada or Mexico does not qualify under USMCA rules of origin, the applicable treatment may differ. Confirm USMCA origin certification requirements with your supplier before relying on this heading. Our article on USMCA Certification of Origin covers the data elements and the one-year refund window in detail.

The 40 percent content threshold

The dividing line between 9903.82.20 and a potentially lower-tier treatment is whether the non-U.S. steel content of the article exceeds 40 percent. This requires knowing the origin of the steel inputs used by your Canadian or Mexican manufacturer. If that data is unavailable, the conservative filing position is to assume non-U.S. steel content exceeds 40 percent and apply 9903.82.20 until you can document otherwise. Verify actual thresholds and any updated note text at hts.usitc.gov.

The 25 percent rate and its effective window

The additional duty rate under 9903.82.20 is 25 percent of the customs value of the entered merchandise. This rate took effect on 2026-06-08 and is scheduled to terminate on 2028-01-01. The rate applies for the entire window between those two dates for subheadings that remain active under this code.

The 25 percent is an additional duty. It stacks on top of the standard column 1 (MFN) rate in Chapters 1-97 and on top of any other applicable Chapter 99 surcharges, with the important exception described in the stacking section below. Use our duty calculator to model the combined landed cost impact for specific subheadings.

The parked subheadings: scope reconciliation as of August 2026

A critical development occurred in August 2026 that every importer and broker filing under 9903.82.20 must understand. A scope reconciliation determined that 9903.82.20 and 9903.82.21 apply only to note 16(c)(xi) derivative steel. A significant number of product subheadings that were initially armed under this code beginning 2026-06-08 actually belong to note 16(c)(ix) or note 16(c)(x) categories, not (c)(xi). As a result, those subheadings were parked, meaning their effective windows were closed (shown in the HTSUS data as windows that opened 2026-06-08 and terminated 2026-06-07, an empty window with no operative period).

What "parked" means for your entry

For parked subheadings, the reconciliation found that applying 9903.82.20 was never lawful. The correct treatment for those goods is the 9903.82.10 floor tier, not the .20/.21 pair. If your goods were entered under a parked subheading with 9903.82.20 claimed between 2026-06-08 and the parking date, you may have entries that need correction. Confirm whether your specific 10-digit subheading is parked or active by checking the current HTSUS at hts.usitc.gov and consulting your broker about protest or post-summary correction options.

The facts block for this article shows the following subheadings among those that were parked (their windows are empty and 9903.82.20 does not apply to them): 8701.94.10, 8708.93.15, 8708.29.21.20, 8701.92.10, 8701.10.01 (note: 8701.10.01 carries a window through 2027-12-31 and is active), and others. Because the facts block covers 40 of 63 total scope entries, and parked vs. active status varies at the subheading level, do not rely on this article alone to determine whether your specific subheading is currently active under 9903.82.20. Check the live HTSUS.

Active subheadings (through 2027-12-31)

The following subheadings are shown in the facts block as carrying active windows from 2026-06-08 through 2027-12-31, meaning 9903.82.20 applies to CA/MX entries for these goods during that period:

• 8429.51.50 (certain self-propelled bulldozers/graders)
• 8701.91.50, 8701.94.50 (certain tractors)
• 8701.10.01 (certain tractors)
• 8429.40.00 (tamping machines and road rollers)
• 8429.11.00, 8429.19.00 (bulldozers and angledozers)
• 8427.10.40, 8427.20.40, 8427.20.80 (fork-lift trucks)
• 8705.10.00, 8705.20.00 (special purpose motor vehicles)
• 8429.52.50, 8429.59.50 (excavating machinery)
• 8431.42.00 (parts for boring or sinking machinery)
• 8429.20.00, 8429.30.00 (graders, scrapers)
• 8429.52.90 (other excavating machinery, check current schedule)

Confirm each subheading at the 10-digit level against the current HTSUS before filing. Subheading descriptions here are provided for orientation only; the official text governs.

How 9903.82.20 appears on an entry and stacks with other duties

Two-line Chapter 99 structure

Chapter 99 codes like 9903.82.20 do not replace your primary classification. On every affected entry line, you report the good's regular Chapters 1-97 subheading on one line and add 9903.82.20 (and its companion 9903.82.21) as additional Chapter 99 lines. CBP's Automated Commercial Environment (ACE) requires both lines to be present. Failure to include the Chapter 99 overlay on a dutiable line is an underpayment; including it on a non-scoped line is an overpayment. Both create post-entry liability. See cbp.gov for ACE filing guidance and any CSMS messages addressing this block.

Stacking with other Section 232 duties

For most scoped goods, the 25 percent under 9903.82.20 stacks on top of the regular column 1 rate. However, the reconciliation that parked certain subheadings revealed a real-world stacking problem: at least one subheading (8708.40.30) had been erroneously stacked with both 9903.82.20 at 25 percent and 9903.74.08 at 25 percent simultaneously, creating a double-232 overcharge. Parking removed that stack; the lawful treatment for that subheading is 9903.74.08 alone. This underscores the importance of verifying that only one Section 232 overlay applies to any given line. If you believe a double-stack occurred on prior entries, raise it with your broker and consider a protest or post-summary correction as appropriate.

For background on how origin affects duty stacking decisions, see our article on China origin substantial transformation.

USMCA interaction

USMCA preferential treatment reduces or eliminates the column 1 MFN rate on qualifying goods. It does not eliminate the Section 232 additional duty imposed under 9903.82.20. The 25 percent applies even when USMCA origin is claimed. USMCA qualification is, however, a prerequisite to being in this specific code's scope in the first place; goods not qualifying for USMCA are outside the .20/.21 pair entirely.

What importers should do

• Verify subheading status before every filing. Check each affected 10-digit subheading against the live HTSUS at hts.usitc.gov to confirm whether it carries an active window under 9903.82.20 or has been parked and reverted to 9903.82.10.
• Audit entries filed between 2026-06-08 and the August 2026 parking dates. If any of those entries included 9903.82.20 on a now-parked subheading, you may have overpaid duty. Work with your broker to evaluate whether a post-summary correction or protest is available, and whether any double-232 stacking errors occurred.
• Document the 40 percent steel content threshold. Obtain and retain supplier certifications or mill certificates that establish the U.S. vs. non-U.S. origin of all steel inputs. This documentation supports both your filing position and any future CBP audit.
• Confirm USMCA certification is current and on file. The heading applies only to USMCA-qualifying goods from Canada or Mexico. Ensure the certification of origin covers the goods and period in question before claiming this treatment.

Key references

• U.S. Harmonized Tariff Schedule (hts.usitc.gov) - Official HTSUS text for 9903.82.20, note 16(c)(xi), and all active subheading windows.
• U.S. Customs and Border Protection (cbp.gov) - ACE filing guidance, CSMS messages on Consolidated Metal 232, and protest procedures.
• Federal Register (federalregister.gov) - Notices and rules establishing and modifying the Consolidated Metal 232 regime.
• White House (whitehouse.gov) - Presidential proclamations underlying Section 232 metal duties.
• 9903.82.18 Consolidated Metal 232: Steel Exemption Heading Explained - The companion exemption code within the same 9903.82 block.
• USMCA Certification of Origin: Data Elements and the One-Year Refund Window - Certification requirements for claiming USMCA treatment on affected entries.
• 2026 Tariff Code Overview - Reference guide to Chapter 99 code changes effective in 2026.