USMCA U.S. Content Rules and HSU 2626 Section 232 Updates

Key Points

• A Federal Register notice dated October 14, 2026, tells CBP exactly how to measure "U.S. content" for USMCA-qualifying goods from Canada and Mexico under Proclamation 11032 of June 1, 2026.
• The U.S.-content calculation matters directly for duty exposure: goods that meet the threshold may receive preferential tariff treatment; goods that do not will face the full tariff imposed by Proclamation 11032.
• Harmonized System Update (HSU) 2626, published in ACE on October 9, 2026, carries four updated harmonized tariff records, 14 ABI records, and Section 232 steel and aluminum changes.
• HSU 2626 also removes the NM8 flag for National Marine Fisheries Service (NMFS) from certain HTS lines, which changes PGA message-set requirements for affected entries.
• Brokers and self-filers must verify their ABI software reflects HSU 2626 before filing entries that cover Section 232 steel or aluminum, or any HTS line that formerly carried the NM8 flag.

On this page

1. What changed: Proclamation 11032 U.S.-content guidance
2. How U.S. content is assessed for USMCA goods
3. HSU 2626: Section 232 tariff record updates
4. HSU 2626: NM8 PGA flag removal
5. Required actions for importers, brokers, and compliance teams
6. Key references

Two overlapping updates hit ACE and the Federal Register in mid-October 2026. The first is official guidance on how CBP will measure U.S. content for USMCA goods subject to the tariffs in Proclamation 11032. The second is CSMS 70197855, which announces HSU 2626 and its Section 232 and PGA flag changes. Both updates affect live entry filings right now. The links throughout this article go to the primary documents themselves: the Federal Register notice and the CBP CSMS message. Read the source.

What changed: Proclamation 11032 U.S.-content guidance

Proclamation 11032, issued June 1, 2026, established tariffs on goods of Canada and Mexico. Clause 2(D) of that proclamation creates a carve-out tied to the share of U.S. content in a product. The October 14 Federal Register notice translates that clause into operational instructions for CBP officers: it specifies what counts as U.S. content, how that content is measured against the value of the finished good, and what documentation importers must present to support a preferential-treatment claim.

The practical consequence is straightforward. If a product of Canada or Mexico qualifies under USMCA and its U.S.-content share satisfies the threshold defined in Clause 2(D), the additional Proclamation 11032 tariff does not apply to that portion. If it does not satisfy the threshold, the full tariff applies. The guidance is CBP's binding interpretation of how that line is drawn at the border.

How U.S. content is assessed for USMCA goods

The Federal Register notice is the controlling document for the methodology. Importers and brokers preparing entries for Canadian or Mexican goods should pull the notice and map their product's cost or value build-up against the specific assessment criteria it describes. Supporting records, such as bills of materials, supplier declarations, and cost data, will be the documentary basis for any U.S.-content claim. CBP officers will use the same notice as their audit checklist, so internal records should align with it precisely.

HSU 2626: Section 232 tariff record updates

CSMS 70197855 confirms that HSU 2626, created October 9, 2026, contains four harmonized tariff records and 14 ABI records tied to Section 232 steel and aluminum. The underlying regulatory basis for those changes is described in the Federal Register document on procedures for steel and aluminum producers committing to new U.S. production. Filers covering Section 232 steel or aluminum entries should confirm that their ABI software has loaded HSU 2626 and that the correct tariff records are resolving before submitting entries. An outdated tariff table can result in incorrect duty calculations or CBP rejection.

HSU 2626: NM8 PGA flag removal

HSU 2626 also removes the NM8 flag, which triggers a National Marine Fisheries Service message set, from certain HTS lines. The CSMS notice does not enumerate every affected line, so importers and brokers who regularly file entries for fish, seafood, or other NMFS-regulated products should review the full HSU 2626 record set to confirm whether their specific HTS numbers are affected. If the NM8 flag has been removed from a line you routinely file, you no longer need to transmit the associated PGA data element for that line, and including it may create a processing conflict. Verify with your ABI software provider that the flag removal has been applied.

Required actions for importers, brokers, and compliance teams

• Read the October 14 Federal Register notice and confirm that your U.S.-content documentation for Canadian and Mexican USMCA goods satisfies the specific methodology CBP will apply under Proclamation 11032 Clause 2(D).
• Verify that your ABI software has loaded HSU 2626 (created October 9, 2026) and that all four updated tariff records and 14 ABI records are active before filing Section 232 steel or aluminum entries.
• Audit your standard HTS filing lines for NMFS-regulated products to determine whether the NM8 PGA flag has been removed, and update your entry templates accordingly.

Key references

• Federal Register: Guidance to CBP Regarding Assessment of U.S. Content Under Proclamation 11032 (Oct. 14, 2026) - the operative CBP methodology for U.S.-content determinations for USMCA goods from Canada and Mexico.
• CSMS 70197855: Harmonized System Update (HSU) 2626 (Oct. 14, 2026) - CBP announcement of Section 232 tariff record updates and NM8 PGA flag removal in ACE.
• Federal Register: Procedures for Steel and Aluminum Producers Committing to New U.S. Production - underlying regulatory basis for the Section 232 record changes in HSU 2626.