ACE Starts Rejecting Copper Wire & Cable Entries on September 14: The Smelt-and-Cast Hard Stop (CSMS #69711865)

ACE Starts Rejecting Copper Wire & Cable Entries on September 14: The Smelt-and-Cast Hard Stop (CSMS #69711865)

On Monday, August 31, at 1:15 p.m. EDT, CBP issued CSMS #69711865, and it is short enough to quote almost in full: "Effective Monday, September 14, 2026, ACE will begin rejecting entry summaries where the copper primary country of smelt and the country of cast are not reported." The error code — F794 ADDTNL DEC TYPE RQRD FOR ARTICLE — becomes a *fatal* version of a message that, since July 30, has been letting entries through.

That is the whole story, and it is a bigger deal than its length suggests. Since the copper smelt-and-cast fields went live in ACE on July 30 (per CSMS #69252300, the July 15 guidance message), brokers who skipped the new 54 record, Type 12 (Copper Smelt and Cast Country Detail) got an error but still got an accepted summary. Eleven days from now, that safety net is gone. An entry summary for a covered copper line without the Type 12 declaration will not file.

If you import insulated copper wire or cable — and that is what these four HTS lines are — you have until the close of business Friday, September 11, to make sure every line item has the data or a deliberate decision about it. This article covers what is actually required, what the "OTH" escape hatch does, and where a bonded warehouse fits when the supplier data isn't there yet.

Which Products Are Covered

The reporting requirement is narrow by HTS code and broad by commercial reach. It applies to imports from every country of origin except the United States classified under:

- 8544.42.10 — insulated electric conductors for a voltage not exceeding 1,000 V, fitted with connectors, fitted with modular telephone connectors - 8544.42.20 — same, fitted with connectors, of a kind used for telecommunications - 8544.42.90 — same, fitted with connectors, other - 8544.49.10 — insulated conductors not fitted with connectors, of a kind used for telecommunications

In plain terms: patch cords, Ethernet and telecom cable assemblies, connectorized power and signal cables, and telecom-grade unterminated cable. This is the heart of the data-center, structured-cabling, consumer-electronics-accessory, and automotive-harness supply chain — product that overwhelmingly ships from China, Vietnam, Mexico, Taiwan, and Malaysia in high line counts per entry. An importer with a 40-line entry of cable assemblies has 40 places to get this wrong.

The requirement traces to Proclamation 11021 (April 2, 2026; 91 FR 18201), the same proclamation that brought copper under Section 232 and created the tiered 50% / 25% / 15% structure we covered when it took effect on April 6. The proclamation directed CBP to collect the countries where the copper in covered articles was smelted and where the article was cast. ACE gained the fields in the certification environment on July 16 and in production on July 30. Until now, enforcement has been advisory.

What You Have to Report

Per CSMS #69252300, on each entry summary line under the four HTS codes above, the filer shall report:

- Primary country of smelt — where the copper was smelted (mandatory) - Country of cast — where the copper article was most recently cast (mandatory) - Secondary country of smelt — optional

The technical vehicle is the Importer's Additional Declaration Type Code 12 on the 54 record, documented in ACE CATAIR Entry Summary Create/Update V109. The ACE error dictionary (V51) added five copper-specific edits: 869 (primary smelt country missing), 870 (primary smelt country unknown), 871 (secondary smelt country unknown), 872 (cast country missing), and 873 (recent smelt country unknown). What changes on September 14 is not those edits — it is that omitting the Type 12 declaration altogether now fails the summary with F794 instead of warning.

If your broker files through a commercial ABI package, confirm two things this week: that the software supports the Type 12 declaration for copper (all major vendors deployed it against the July 16 certification date), and that your line-level product data actually feeds it. Field support and data population are different problems, and most rejections on September 14 are going to be the second one.

The "OTH" Escape Hatch — and Why It Is Not a Strategy

Both CSMS messages say the same thing: if the primary country of smelt, secondary country of smelt, and/or country of cast are not known, importers may report "OTH" (other). That means, on paper, no covered entry ever has to be rejected — a filer can populate every Type 12 field with OTH and clear the F794 edit.

Three cautions before you make OTH your default.

First, precedent. When CBP built the equivalent smelt-and-cast fields for aluminum under Section 232, it paired the "unknown" option with a consequence: entries reporting unknown countries of smelt and cast were assessed at the 200% Russian-origin aluminum rate. The copper guidance does not attach a rate penalty to OTH today. It also does not promise there never will be one. The whole point of Proclamation 11021's data collection is to find out where the copper is coming from; a field full of OTH is the outcome the proclamation was written to prevent.

Second, reasonable care. 19 U.S.C. 1484 obligates the importer of record to use reasonable care in providing information to CBP. Reporting OTH when the supplier could have told you the smelter with one email is a different posture than reporting OTH after a documented, unsuccessful inquiry. Keep the inquiry.

Third, commercial reality. Most smelt and cast data is available. Cable assemblers buy drawn copper wire from a small set of rod mills, and rod mills know their cathode source. The information exists — it just has never been asked for on a per-line basis at entry. The exercise this week is a supplier questionnaire, not a mystery.

What Happens When an Entry Summary Is Rejected

A rejected summary is not a seized shipment, but it is not harmless either. Cargo release and entry summary are separate transactions in ACE; if release was granted, the cargo is already yours. The summary, with duties, is due within 10 working days of release. A summary that ACE rejects on September 14 and that the broker cannot re-file with valid Type 12 data by day 10 is a late-filed summary — which means liquidated damages exposure under your continuous bond, and, for repeat offenders, the kind of pattern that draws a CBP Form 28.

Where it gets expensive is the other order of operations: goods that have arrived but have not been released because the filer is holding the entry until the data problem is solved. Merchandise not entered within 15 calendar days of arrival goes to General Order under 19 CFR 127 — CBP moves it to a bonded GO warehouse at your expense, and after six months without entry it is sold at auction. Our General Order guide walks through what that actually costs at the Port of Charleston. It is never cheaper than solving the problem on day one.

Where a Bonded Warehouse Fits

For cable importers who are also carrying the Section 232 copper layer on the same lines — 25% on the full customs value for derivative copper articles under the April 6 structure, or 50% for base-metal articles — a customs bonded warehouse solves two problems at once.

It stops the duty clock. A warehouse entry (type 21) moves the goods off the pier and into bonded storage without duty being assessed. The Section 232 copper duty, the ordinary Chapter 85 rate, and any Section 301 layer are all deferred until a withdrawal for consumption (type 31) — which can be filed line by line, SKU by SKU, as the goods are sold. Goods that are re-exported from the warehouse never owe U.S. duty at all. For a $600,000 entry of Chinese cable assemblies carrying Section 232 at 25% and Section 301 at 25%, that is roughly $300,000 of duty that does not have to be financed on the day the container lands.

It stops the General Order clock. A type 21 entry *is* an entry. Once the goods are in bond, the 15-day GO countdown is satisfied, and the merchandise can remain in the warehouse for up to five years from the date of importation.

What it does not do is make the smelt-and-cast requirement go away. The Type 12 declaration attaches to the entry summary line, and a warehouse withdrawal for consumption generates an entry summary. Read the bonded route for what it is: a way to get the container out of the terminal, out of demurrage, and out of GO exposure while your supplier produces the smelter and caster documentation — so that when you do file for consumption, the line reports a real country instead of OTH. For product that turns out to be uneconomic to enter at the stacked duty rate, the same warehouse is the exit door to a third market without the duty ever being paid.

Importers rebuilding line-level landed-cost models against the Section 232 copper stack — and now against a reporting requirement that has to be satisfied per line — often run classification and duty math through software such as Zonos before deciding which SKUs get entered, bonded, or re-routed. (Disclosure: this is an affiliate link — FreightFigures may earn a commission if you sign up, at no additional cost to you. See our full affiliate disclosure.)

An 11-Day Checklist

By Friday, September 4: Pull every entry filed since July 30 under 8544.42.10, .20, .90 and 8544.49.10. Check whether the Type 12 declaration was populated and with what. Any line showing OTH or blank is a line that needs supplier data.

By Wednesday, September 9: Send a smelt-and-cast questionnaire to every supplier of covered product. Ask for the primary smelter (company and country) of the copper conductor and the country where the article was cast, per part number. Keep the responses — they are your reasonable-care file.

By Friday, September 11: Confirm with your broker that Type 12 is mapped in their ABI software and that your part master carries the fields. Test-file a summary in ACE certification if your filer can.

For containers arriving September 14 onward without data: Decide *before* arrival whether the line files with OTH (documented inquiry in hand), or goes in under a type 21 warehouse entry to buy time and defer the duty. Do not let the decision get made for you by the 15-day GO clock.

Estimate the duty you would be deferring with the Duty Deferral Calculator, or model the full Section 232 + 301 stack on a cable entry with the Tariff Stacking Calculator.

FAQ

What changes on September 14, 2026 for copper imports? ACE will reject — not merely warn on — entry summaries for HTS 8544.42.10, 8544.42.20, 8544.42.90 and 8544.49.10 that do not report the primary country of smelt and country of cast via the Importer's Additional Declaration Type 12. The F794 error becomes fatal (CSMS #69711865, issued August 31, 2026).

Can I report "OTH" if I don't know where the copper was smelted? Yes. CBP guidance permits OTH for unknown primary smelt, secondary smelt, and cast countries. There is currently no rate penalty for OTH on copper, unlike the 200% assessment CBP applies to unknown smelt-and-cast on aluminum — but OTH should follow a documented supplier inquiry, not replace one.

Does the requirement apply to all copper products? No. It applies only to the four HTS lines above — connectorized insulated conductors under 8544.42 and telecom-grade unterminated conductors under 8544.49.10 — from all origins except the U.S.

Does putting the goods in a bonded warehouse avoid the smelt-and-cast reporting? No. The declaration attaches to the entry summary line, and a warehouse withdrawal for consumption generates an entry summary. What a bonded warehouse does is take the goods off the pier under a type 21 entry — stopping demurrage, the 15-day General Order clock, and the Section 232 / 301 duty assessment — while you obtain the data from your supplier.

What happens if my entry summary is rejected and I can't fix it in time? The summary is due within 10 working days of cargo release. A summary not accepted by then is late-filed, exposing the importer to liquidated damages under the continuous bond. If the goods were never released and no entry is filed within 15 days of arrival, they go to General Order.

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