A growing number of entries now carry two, three, or more Chapter 99 classifications on the same line: a Section 301 tariff, a Section 338 tariff, a Section 232 tariff, sometimes all at once. When that happens, CBP requires those classifications to be reported in a specific order on the entry summary line in ACE. Getting the sequence wrong can result in a rejected filing, an incorrect duty calculation, or a forfeited exclusion claim.
CBP reissued this guidance on August 27, 2026 (CSMS #69668138), updating the reporting order to reflect the current lineup of active trade remedies. The underlying structure isn’t new, but the specific sequence changes as remedies are added or removed, which makes this a good moment for importers and brokers to confirm their internal procedures reflect the current order rather than an older version.
The Full HTSUS Reporting Sequence
When an entry summary line claims a heading or subheading in Chapter 98 and/or Chapter 99, CBP requires the classifications to be reported in this order:
- Chapter 98 classification, if applicable
- Chapter 99 classification(s) for additional duties, if applicable
- For trade remedies, in this order: Section 301, then Section 338, then Section 232, then Section 201 duties (if applicable), then Section 201 quota (if applicable)
- Chapter 99 classification(s) for replacement duty or other use, such as a Miscellaneous Tariff Bill provision or other applicable provision
- Chapter 99 classification for other quota not already covered above, if applicable
- The Chapter 1-97 classification for the underlying commodity
The entered value should generally be reported on the Chapter 1-97 classification, unless a Chapter 98 reporting provision requires the entered value to be reported differently.
A Worked Example
Consider a shipment of steel articles from a country subject to both a Section 301 tariff and the Section 232 steel tariff, with no Chapter 98 provision or quota involved. On the entry summary line, the classifications should be reported in this order:
- The Chapter 99 classification for the Section 301 tariff
- The Chapter 99 classification for the Section 232 tariff
- The Chapter 1-97 classification for the steel article itself, carrying the entered value
If a Section 338 tariff also applied to the same product, its Chapter 99 classification would be reported between the Section 301 and Section 232 classifications, consistent with the sequence above. Reporting these out of order, or omitting one of the applicable Chapter 99 classifications, is a common cause of ACE rejections and duty miscalculations on layered-remedy entries.
Where Filers Go Wrong
- Treating an older version of the sequence as current. CBP has reissued this same guidance periodically as trade remedies change; a sequence memorized a year or two ago may no longer reflect where Section 338 or other newer remedies fall in the order.
- Omitting a Chapter 99 classification because it seems redundant with another. Each applicable trade remedy generally needs its own Chapter 99 classification reported in sequence, not folded into a single line item.
- Reporting the entered value on the wrong classification. Absent a Chapter 98 exception, the entered value belongs on the Chapter 1-97 classification, not on a Chapter 99 trade remedy line.
- Assuming the sequence is the same across all trade remedy combinations. The order among Section 301, 338, 232, and 201 is fixed; it does not vary by product or by which remedies happen to apply to a given shipment.
What Importers and Brokers Should Do
- Confirm current internal filing instructions and broker guidance reflect the sequence in CSMS #69668138, not an earlier version.
- Audit recent entries involving stacked trade remedies (particularly Section 301 combined with Section 338 or Section 232) for correct classification order.
- Route filing errors to a CBP client representative or the ACE Help Desk, and direct trade remedy sequencing questions to CBP’s Trade Remedy Branch.
- Revisit this sequence whenever a new trade remedy proclamation takes effect, since the order can shift as remedies are added.
ASK ALBA™
Contact the Alba team for assistance reviewing entry summary sequencing, trade remedy stacking, or ACE filing errors related to Chapter 98 or 99 classifications.
Contact Alba to speak with a trade compliance expert
References
CBP Cargo Systems Messaging Service (CSMS message search)
CBP Section 232 Tariffs on Steel and Aluminum: Frequently Asked Questions
