On August 31, 2026, U.S. Customs and Border Protection (CBP) issued CSMS #69711865: beginning Monday, September 14, 2026, the Automated Commercial Environment (ACE) will reject entry summaries for covered copper articles when the primary country of smelt and the country of cast are not reported. The data itself is not new — it has been required since July 30, 2026. What changes on September 14 is that ACE stops letting the entry summary through without it. If you have been importing under any of four specific wire and cable classifications and treating a soft warning as noise, you have about a week, as of this writing on September 7, 2026, to close the gap.
What Actually Changes on September 14
CBP's message is narrow and specific. As of Monday, September 14, 2026, the ACE error F794 ADDTNL DEC TYPE RQRD FOR ARTICLE becomes the fatal version of that error when the required 54 record — Importer's Additional Declaration Type Code 12, "Copper Smelt and Cast Country Detail" — is not submitted on a covered entry summary.
That single word, fatal, is the whole story. ACE returns two broad classes of condition on a transmitted entry summary. A non-fatal condition is informational: the filing is accepted, the entry summary is on file, and the message sits in your response as something to look at later. A fatal condition means the transmission is rejected. The entry summary is not on file. Nothing downstream of it — no duty calculation, no liquidation clock, no release paperwork that depends on a summary being accepted — proceeds until you correct the data and retransmit.
So the population most exposed here is not importers who have never heard of the requirement. It is importers who have been transmitting these entry summaries successfully since late July while quietly accumulating a warning nobody triaged. Those filings worked. On September 14, the identical transmission stops working.
CBP directed questions on this change to its Entry Summary Accounts and Revenue Division. The message does not describe any grace period, phase-in, or transition window past the September 14 effective date.
The Four HTSUS Numbers — and Why You May Not Think They Are Yours
Both CSMS #69711865 and the earlier CSMS #69252300 name the same four Harmonized Tariff Schedule of the United States (HTSUS — the classification system that sets duty rates and import requirements for every imported article) numbers:
- 8544.42.10 — fitted with modular telephone connectors
- 8544.42.20 — fitted with connectors, of a kind used for telecommunications
- 8544.42.90 — fitted with connectors, other (a basket that includes extension cords under the chapter's statistical note 7)
- 8544.49.10 — not fitted with connectors, of a kind used for telecommunications
Read the parent heading and the practical problem gets obvious. Heading 8544 covers "insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors," along with certain optical fiber cables. These are not copper mill products. They are patch cords, telecom cable, wiring harnesses, connectorized cable assemblies, and extension cords — finished electrical goods in Chapter 85, several chapters away from the raw copper in Chapter 74.
An importer bringing in pallets of Ethernet patch cables does not usually think of themselves as a copper importer, does not have a relationship with a smelter, and has never asked a supplier where the cathode came from. Under Proclamation 11021 and Section 232 of the Trade Expansion Act of 1962, that importer is nonetheless the party responsible for declaring the primary country of smelt and the country of cast on every one of those entries. If you classify anything into these four numbers, this is your requirement whether or not copper appears anywhere in your product catalog description.
If your classifications for cable assemblies have not been reviewed recently, that review has just become time-sensitive for a second reason. Our HTS classification guide walks through how to pressure-test the codes you are already using.
The Requirement Has Been Live Since July 30
CBP announced the underlying reporting obligation in CSMS #69252300 on July 15, 2026, with an effective date of July 30, 2026. It requires importers to report the countries where the copper used in the manufacture of covered copper article imports was smelted, plus the information needed to identify where those articles were cast. The authority is Presidential Proclamation 11021, issued under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862) — the same national-security statute behind the steel, aluminum, and copper tariff programs generally.
That July message also added five new copper-specific error codes to the ACE entry summary error dictionary. Those codes flag a missing primary smelt country, a missing cast country, and unknown-country conditions on the smelt and cast fields. They have been firing since July 30. The August 31 message does not create a new obligation; it removes the cushion under the existing one.
The distinction matters for how you triage this internally. If your filings have been clean since July 30, September 14 is a non-event for you. If they have not, you have been running for roughly six weeks on a tolerance that expires next Monday. Between those two states there is no third option where the entries keep flowing untouched.
Section 232 programs have a habit of adding data elements to entries that previously carried none, and the elements tend to arrive before the enforcement does. Our 2026 tariff stacking guide covers how Section 232, Section 301, and antidumping and countervailing duty programs interact on a single entry line, which is the wider context this sits in.
What the 54 Record Has to Carry
The declaration itself is short. Per CBP's messages, a covered entry summary needs the 54 record carrying Importer's Additional Declaration Type Code 12, and that record reports:
- Primary country of smelt — required.
- Country of cast — required.
- Secondary country of smelt — optional. CBP's August 31 message states plainly that the secondary country of smelt remains optional, so a filing is not incomplete for lacking it.
CBP also provides an explicit escape valve: OTH may be reported when the primary country of smelt, the secondary country of smelt, and/or the country of cast is not known. That is CBP's own stated allowance, not a workaround.
Treat OTH as a valid entry and a poor destination. It is the difference between an entry summary that transmits and one that does not, and on September 14 that difference is worth having available. It is also a declaration that you do not know something about your own supply chain, made on a filing you signed as importer of record. CBP's copper messages address the reporting mechanics only; they say nothing about how the agency evaluates OTH after the fact, and neither will we. The defensible position is to use it where the data genuinely does not exist yet and to keep working the supplier for the real answer.
The Week You Have Left: A Working Checklist
Seven days is enough time to close this if you start from your own data rather than from your supplier's inbox.
1. Pull your own exposure. Run an entry report for the last 90 days filtered to 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10. If any line is there, you are in scope. Include entries in flight, not just filed ones.
2. Read your ACE response messages. Go back through your ABI (Automated Broker Interface — the CBP-certified channel through which filers transmit to ACE) responses since July 30 and look for F794 and the copper smelt and cast error codes. Warnings you have been ignoring are a precise, free list of the entries that will stop working next Monday.
3. Confirm your software actually builds the record. Ask your filing software vendor, in writing, whether it supports the 54 record with Additional Declaration Type Code 12 and where in the workflow the smelt and cast fields are populated. Supporting a record and defaulting it correctly on your entries are two different things.
4. Ask suppliers the specific question. Not "where is this made" — country of manufacture is a different data point. Ask for the primary country of smelt and the country of cast for the copper conductor in each part number. Mill test certificates and supplier origin declarations are the usual place that information lives.
5. Decide your fallback per part number, before you need it. For any part where the answer will not arrive by September 14, decide now whether you are filing OTH and who is accountable for chasing the real value afterward.
6. Test-file early in the week. Transmit a covered summary with the 54 record populated before Monday if your volume allows it, so the first time you exercise the record is not the morning entries start bouncing.
If you file your own entries, items 3 and 6 are yours to build and worth doing this week; self-filing runs $30 per entry with Strix, and the cost of this change is configuration time, not filing fees. If a broker files for you, send items 1 and 2 to them today and ask them to confirm in writing how the 54 record will be populated on your entries starting Monday. Full brokerage runs $100–$250 per entry depending on complexity, and this is exactly the kind of new data element your broker should be raising with you before you raise it with them.
If You Already Filed Without the Data
Entries transmitted before September 14 without smelt and cast detail were accepted — that is what a non-fatal condition means. They are on file. The question is whether the declaration on them is complete and accurate, and that question does not go away because the filing succeeded at the time.
The standard mechanism for correcting an accepted entry summary before liquidation is a post summary correction (PSC), an electronic amendment to an entry summary already on file with CBP. Whether a given omission or a placeholder value calls for one is a judgment call for your licensed broker on the specific entry; CBP's two copper messages address transmission requirements and say nothing about post-filing correction of this data element, and we are not going to extrapolate a CBP position that CBP has not stated. What we can tell you is the process and the cost: PSC filing with Strix is $150 per entry for up to ten lines, and our PSC filing guide and post summary corrections page cover eligibility windows and how the filing works.
The point of raising it now is sequencing. Fix the forward-looking transmission first so entries keep moving after September 14, then work backward through what was already filed. Doing it in the other order means solving a paperwork problem while your current shipments sit.
CSMS #69711865 and CSMS #69252300 both name four HTSUS numbers for this requirement: 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10. Those are the codes covered by the September 14 fatal-error change. Section 232 copper measures are broader than these four codes, so if you import other copper articles, confirm your specific classifications with your filer rather than assuming this message defines your full obligation.
What if I genuinely do not know where the copper was smelted?
CBP allows OTH to be reported when the primary country of smelt, the secondary country of smelt, and/or the country of cast is not known. That keeps the entry summary transmittable. It is a stated CBP allowance, not an exemption from knowing, and it should come with an internal owner and a date by which you expect the real value from your supplier.
Do I have to report a secondary country of smelt?
No. CBP's August 31, 2026 message states that the secondary country of smelt remains optional. Only the primary country of smelt and the country of cast are required for the 54 record to satisfy the check that becomes fatal on September 14.
My broker files my entries. Is this still my problem?
Operationally you share it; substantively the data is yours. This is an Importer's Additional Declaration, and the importer of record is the party who has — or does not have — a supplier relationship that can produce a smelt and cast country. Your broker transmits the record; only you can source what goes in it. Send them your covered part numbers and the values this week rather than waiting for a rejection to start the conversation.
Get Ahead of Monday
Four HTSUS numbers, two required fields, one week. That is a small enough problem to solve cleanly if you start from your own entry data, and a genuinely disruptive one if the first sign of it is a rejected entry summary on the morning of September 14.
Strix works four ways on a change like this. We clear — licensed brokers filing your entries with the 54 record populated correctly. We consult — a review of whether your classifications actually land in these four codes and what your smelt and cast data gaps are. We comply — building the supplier-data process so OTH is a temporary answer instead of a standing one, plus PSC filing on entries already on file. And we automate — self-filing software that carries the copper declaration through ACE without hand-keying it on every entry, which our self-filing solution page describes in full.
If you import wire, cable, or connectorized cable assemblies and you are not certain where your smelt and cast data stands, talk to our team this week rather than next.