Importers of certain copper articles have had to report the country where their copper was smelted and cast since July 30, 2026. Starting September 14, 2026, that requirement gets teeth: CBP has announced that ACE will begin hard-rejecting entry summaries that omit the required data, meaning affected cargo won’t clear without it.
CBP issued the enforcement update on August 31, 2026 (CSMS #69711865). If your supply chain touches covered copper products and you haven’t confirmed your suppliers can provide smelt and cast country information, now is the time.
Where This Requirement Came From
The copper smelt and cast reporting requirement traces back to Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” signed April 2, 2026, which extended the existing Section 232 metals tariff regime to cover copper articles and their derivatives.
The proclamation directed CBP to collect information identifying where the copper used in covered imports was smelted and where it was cast, mirroring reporting requirements already in place for aluminum. CBP issued detailed guidance on July 15, 2026 (CSMS #69252300), and the ACE reporting fields became mandatory in production on July 30, 2026.
What Importers Have Had to Report Since July 30
Since July 30, 2026, importers of certain copper articles from all countries of origin except the United States have been required to report on the entry summary line:
- The primary country of smelt (required)
- The country of cast (required)
- A secondary country of smelt (optional, where applicable)
The requirement applies to entries under the following HTSUS classifications:
- 8544.42.10
- 8544.42.20
- 8544.42.90
- 8544.49.10
Where the primary country of smelt, secondary country of smelt, or country of cast is not known, importers have been permitted to report “OTH” (other) in place of a specific country code.
What Changes on September 14
Until now, the July 30 reporting fields have been mandatory but the consequences of omitting them have varied. Effective September 14, 2026, ACE will issue a fatal F794 error (“ADDTNL DEC TYPE RQRD FOR ARTICLE”) and reject any entry summary for covered copper products that does not include the required Type 12 record (Copper Smelt and Cast Country Detail).
In practical terms, a rejected entry summary means the cargo does not clear until the filing is corrected and resubmitted. This is a materially different risk than a warning or a correctable error after the fact.
The “OTH” reporting option remains available for importers who genuinely cannot determine the smelt or cast country. It does not disappear on September 14. What disappears is the ability to omit the field altogether.
What Importers Should Do Now
- Identify all copper shipments classified under HTSUS 8544.42.10, 8544.42.20, 8544.42.90, or 8544.49.10.
- Contact suppliers now to confirm they can provide primary country of smelt and country of cast information, and secondary country of smelt where applicable.
- Where supplier data is genuinely unavailable, confirm your filing process is set up to report “OTH” rather than omitting the field.
- Test ACE filings for covered copper entries before September 14 to confirm the Type 12 record transmits correctly and avoid a rejection on a live shipment.
- Review internal SOPs and broker instructions to make sure the smelt and cast fields are a standard part of the entry summary workflow for covered HTSUS lines, not a manual add-on.
- Coordinate with your customs broker on how rejected entries will be corrected and resubmitted if a filing is caught by the new F794 error.
ASK ALBA™
Contact the Alba team for assistance confirming copper smelt and cast country data with your suppliers, reviewing ACE filing procedures, or evaluating Section 232 copper exposure.
Contact Alba to speak with a trade compliance expert
References
CSMS #69711865: Copper Additional Smelt and Cast Country Detail Error Code Update (Aug. 31, 2026)
CSMS #69252300: Guidance: Section 232 Copper Smelt and Cast Reporting Requirements (July 15, 2026)
CBP Section 232 Tariffs on Steel and Aluminum: Frequently Asked Questions
