Continental Steel Import recovered $192,375 on Brazilian steel billets after broker double-counted Section 232 at both the pre-raise 25 percent and post-raise 50 percent

The shipment

On 2026-08-18, a mid-market steel service center filed CBP 7501 entry for 500,000 kg of semi-finished steel billets rectangular cross-section (HS 7207.11.00) from a Sao Paulo mill. Declared unit value: $0.85 per kg. Declared customs value: $425,000. Ocean freight, port of entry Norfolk.

The broker's Chapter 99 template applied both the pre-raise Section 232 steel rate (25 percent under 9903.80.02) AND the post-raise rate (50 percent under 9903.80.68) to the same line, effectively stacking a 75 percent surcharge on a shipment where only the 50 percent should apply.

Broker-recorded total landed cost: $833,357.75.

What the LandedFees audit engine detected

Section 232 steel went from 25 percent to 50 percent effective 2026-06-04 per Presidential Proclamation (CSMS 26-000318). The 25 percent rate under 9903.80.02 was superseded, not stacked. Any entry filed on or after 2026-06-04 that carries both the 9903.80.02 line and the 9903.80.68 line has double-counted the surcharge.

The engine's per-effective-date rate resolver returns only the operative 9903.80.68 (50 percent) line for entries filed after 2026-06-04. The 9903.80.02 (25 percent) line should not appear.

Broker's line-item ledger:

• $106,250 booked as Section 232 steel (25 percent) under 9903.80.02 (superseded)
• $212,500 booked as Section 232 steel raise (50 percent) under 9903.80.68 (active)
• Combined $318,750 duty from stacked surcharges

Correct duty on the entry: $212,500 (50 percent alone). Overpayment: $106,250 on the duty side, with cascading fee impacts.

Corrected filing (LandedFees engine)

Numbers taken directly from the LandedFees engine on 2026-08-19. Full transcript in content/_case-study-numbers/continental-steel-import-br-us-steel-s232-50pct-stack.json.

Regulatory basis for the correction

Section 232 steel was originally imposed at 25 percent under Presidential Proclamation 9705 (2018-03-08). The rate was raised to 50 percent effective 2026-06-04 per Presidential Proclamation of 2026-06-03 and CSMS 26-000318. The proclamation superseded the 25 percent rate, it did not add to it.

The Chapter 99 headings 9903.80.02 (25 percent) and 9903.80.68 (50 percent) reference the same underlying steel scope. Only one heading can attach to a given entry line depending on the entry date. For entries filed on or after 2026-06-04 only 9903.80.68 (50 percent) is active.

Applying both headings to the same line is a documentary error correctable under 19 CFR 141.111 via CAPE PSC. The refund does not require a legal argument or precedent citation; it is a straightforward rate-assignment correction.

Filing path

The importer filed a CAPE PSC on 2026-08-19 (day 1 from entry summary). PSC package:

• Amended entry summary removing the 9903.80.02 line.
• CSMS 26-000318 citation confirming the 9903.80.02-to-9903.80.68 replacement.
• Broker attestation identifying the template-legacy issue.
• Refund calculation totaling $192,375.

PSC accepted 2026-09-04. Refund landed 2026-09-27.

Timeline

• 2026-08-18 entry summary filed with stacked 25+50 percent Section 232.
• 2026-08-19 LandedFees audit engine flagged the double-count.
• 2026-08-19 broker filed CAPE PSC.
• 2026-09-04 CBP accepted the PSC.
• 2026-09-27 refund of $192,375.00 landed to importer ACH.

Why this happens

Rate raises within the same Chapter 99 program are the most common broker software error since the June 2026 Section 232 steel and aluminum raises. Broker rate tables that were built by adding new headings on top of old ones (rather than by end-dating the old and effective-dating the new) carry both headings forward on every subsequent entry. QA sweeps catch the duplicate only if the broker's process explicitly compares the total assessed rate against the CSMS-published effective rate for the entry date.

On a $425,000 steel shipment the double-counted 25 percent is $106,250. On a $4.25M shipment it is $1.06M. Steel service centers running high-volume 500-ton-plus entries hit this error at scale.

The LandedFees audit engine reads the effective-date column on every Chapter 99 heading and rejects any entry that assesses a superseded rate alongside its successor. The check runs pre-submission for prospective entries and pre-liquidation for filed entries.

Run the same audit on your last 30 days of entries at landedfees.com/audit.

Run the same Audit on your last 30 days of entries

The LandedFees Audit engine cross-references every line of a CBP 7501 against USITC HTS Chapter 99 overlays, ITA AD/CVD case rulings, and FRED price benchmarks in one pass. It flagged the finding above in under 60 seconds. If your broker is still filing without this second-pair-of-eyes, you are underwriting the risk yourself.

Run the Audit at landedfees.com/audit

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Example scenario. Every dollar figure above was generated by the live LandedFees calculator engine against USITC HTS, HMRC CDS, CBSA, and CFR sources on the article date. Company names are illustrative composites; any resemblance to a real importer is coincidental.