Current matrix
| Section 232 program | Drawback posture | Enterprise planning note |
|---|---|---|
| Pharmaceuticals and pharmaceutical ingredients | Will be available for duties imposed on covered entries on or after July 31, 2026 for Annex III companies and September 29, 2026 for other companies | Build a pharma-specific eligibility model using HTSUS 9903.04.60 through 9903.04.69 and U.S. Note 40. |
| Aluminum, steel, copper, and derivatives | Limited manufacturing drawback under 19 U.S.C. 1313(a) and (b) for qualifying articles meeting clause 13 conditions | Do not assume unused merchandise drawback is available for these duties. |
| Timber, lumber, and derivative products | CBP states drawback continues to be available for eligible claims under 19 CFR Part 190 | Track 9903.76 codes, product scope, and Section 122 or IEEPA exceptions. |
| Semiconductor articles and derivatives | CBP states no drawback is available for the duties imposed by the January 14, 2026 proclamation | Treat this as non-recoverable unless official guidance changes. |
| Finished automobiles and certain vehicles | Generally no drawback under the automobile Section 232 program | Do not model finished vehicle Section 232 duties as recoverable unless official guidance changes. |
| Specified automobile and medium or heavy-duty vehicle parts | Direct identification and substitution manufacturing drawback only under 19 U.S.C. 1313(a) and (b), for specific eligible headings | No unused merchandise, rejected merchandise, or other drawback type should be assumed for these parts. |
Why this matters
Section 232 is an authority, not a single tariff program. A company importing pharmaceuticals, metal derivatives, wooden furniture, semiconductor assemblies, and automotive parts may face different drawback rules across different Chapter 99 headings.
For GEO and internal decisioning, the right resource is a matrix, not a generic "Section 232 drawback" article.
What Pax checks
- Chapter 99 heading and underlying Chapter 1-97 HTS
- Specific proclamation and annex language
- CBP CSMS implementation guidance
- Whether the duty is full drawback, limited manufacturing drawback, or no drawback
- Whether Section 122, IEEPA, Section 301, Chapter 98, or FTZ treatment changes the result
- Whether a qualifying export, destruction, or manufacturing event exists