Section 232 tariffs on steel and aluminum products extend to certain scrap forms under specific HTS subheadings. Whether a particular scrap shipment is covered depends on its HTS classification — the alloy content, form, and processing state all factor into whether the article falls within the scope of the relevant proclamation. Importers should verify current scope guidance from the Department of Commerce and CBP before assuming a scrap grade is exempt.

Under RCRA, certain secondary materials that exhibit hazardous characteristics may be regulated as hazardous waste rather than as legitimate scrap, triggering EPA import notification and consent requirements. The distinction between a 'hazardous waste' and a 'hazardous secondary material' being legitimately recycled is fact-specific and depends on how the material is managed. Importers of industrial scrap with potential contamination should consult with environmental counsel alongside their customs broker before entry.