Section 232 metals duties split by entry date, and the protest clock runs off liquidation
The Proclamation 11021 split is the most time-sensitive item in this issue, because the controlling line is the entry or warehouse-withdrawal date while the 180-day protest clock runs off liquidation. Importers should map every open metals entry across both axes before choosing a protest theory. Pre-April 6 entries preserve content-based duty-base arguments, and post-April 6 entries generally face full-customs-value assessment and need a different challenge posture.
Proclamation 11021 splits Section 232 metals duties by entry date rather than liquidation date. Goods entered for consumption, or withdrawn from warehouse for consumption, before one minute after midnight EDT on April 6, 2026 stay in the content-based duty cohort, where valuation and metal-content arguments can still matter. Goods entered or withdrawn on or after that moment are generally assessed on full customs value. Liquidation date runs a separate axis, the 180-day protest window under 19 U.S.C. 1514, so each open entry has to be read against both dates before anyone selects a protest theory.
USMCA nonrenewal in 2026 leaves the agreement in force rather than terminating it. Ending USMCA preferential duty treatment before the 2036 sunset would take a separate withdrawal or termination step, and the domestic authority to give that notice and alter statutory duty treatment remains unresolved. Until that question is settled, the duty consequences of a decision to leave USMCA cannot be assumed to follow automatically. Sourcing teams modeling exposure under a post-USMCA scenario should treat the authority gap as a live variable rather than a settled outcome.