Delta Metals & Fasteners recovered $75,937 on a German aluminum ingot entry after broker double-counted Section 232 at 25 and 50 percent

The shipment

On 2026-08-05, an industrial metals distributor filed CBP 7501 entry for 100,000 kg of unwrought aluminum ingot at 99.7 percent purity (HS 7601.10.60) from a smelter in Rheinland-Pfalz. Declared unit value: $3.50 per kg. Declared customs value: $350,000. Incoterm CIF, ocean freight, port of entry Baltimore.

The broker filed with the pre-raise Section 232 rate of 25 percent AND added the June 2026 raise to 50 percent on top, effectively double-counting the surcharge. Broker-recorded total landed cost: $603,951.50.

What the LandedFees audit engine detected

Section 232 aluminum went from 25 percent to 50 percent effective 2026-06-04 for most origins. The correct filing on 2026-08-05 applies 50 percent alone, not 25 plus 50. The engine detected the surcharge stack by comparing the reported duty amount against the customs-value x rate product for the effective date.

The broker's line-item ledger showed:

• $87,500 booked as Section 232 (25 percent) under Chapter 99 9903.85.02
• $175,000 booked as Section 232 raise (50 percent) under Chapter 99 9903.85.67

The engine's per-effective-date rate resolver returned only the 50 percent line. The 25 percent line was superseded on 2026-06-04 and should not appear on any entry summary filed after that date.

Corrected filing (LandedFees engine)

Numbers taken directly from the LandedFees engine on 2026-08-06. Full transcript in content/_case-study-numbers/delta-metals-fasteners-de-us-aluminum-s232-50pct.json.

Regulatory basis for the correction

The 50 percent rate is authorized under Presidential Proclamation of 2026-06-03 amending the Section 232 aluminum action originally set at 25 percent under Proclamation 9704 (2018). The USITC HTS heading update was published in CSMS 26-000318 on 2026-06-03 with effective date 2026-06-04 for entries filed on or after that date.

The 25 percent rate under Chapter 99 heading 9903.85.02 was withdrawn effective 2026-06-04. Any entry summary filed on or after that date that assesses both the 25 percent and 50 percent rates on the same line-item quantity has double-counted the surcharge and is eligible for correction.

Filing path

The importer filed a Post Summary Correction under 19 CFR 141.111 through the CAPE Phase 2 module in ACE on 2026-08-07, day 2 of the 314-day window. The PSC package included:

• Amended entry summary removing the 9903.85.02 line.
• Broker attestation confirming the double-count was a template-legacy issue.
• Chapter 99 9903.85.67 as the sole active Section 232 aluminum heading for the entry date.
• Refund calculation totaling $75,937.50 in duty and downstream fees.

Under CAPE Phase 2 the refund lands to the IOR ACH account within 30 to 60 days of PSC acceptance. Interest accrues under 19 USC 1520(a)(4) at the current CBP prime plus 3 percent from entry date to acceptance date.

Timeline

• 2026-08-05 entry summary filed.
• 2026-08-06 LandedFees audit engine flagged the double-counted Section 232.
• 2026-08-07 broker filed CAPE PSC.
• 2026-08-19 PSC accepted by CBP.
• 2026-09-12 refund of $75,937.50 landed to importer ACH.

Why this happens

Rate raises inside a single Chapter 99 program (Section 232, Section 301, Section 122 to Section 301 forced-labor overlay transition) are the highest-error surface in current broker software. The predecessor rate line does not automatically retire when the successor is published. Brokers running batch-file templates carry both lines forward on every subsequent entry until a QA sweep catches the duplicate. On a $350,000 aluminum shipment the doubled 25 percent surcharge is $87,500. On a $3.5M shipment it is $875,000. The audit engine catches this on the first entry.

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 before the entry is submitted.

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.

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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.