Issue link: https://iconnect007.uberflip.com/i/1535954
28 SMT007 MAGAZINE I JUNE 2025 steel and/or aluminum, which now include many electronic products and components. Compliance becomes particularly challenging because only the percentage of steel and/or alu- minum content of those derivative products is subject to the tariffs, so that content per product must be broken out specifically. ey have to go to their suppliers, and their suppliers have to go down the supply chain to figure out the raw steel and aluminum in a PCB or similar product. Marcy LaRont: Is there already a template, a formulation, for that type of calculation? Because the guidance on this has been scarce, and the government hasn't provided a way for companies to work with their suppliers, each industry is developing solutions to stream- line that process. We're seeing standardization regarding solicitation requests made to sup- pliers with the data elements their customers need to meet these requirements. ere are many things to consider, such as calculating the amount of steel and aluminum, and tracing the steel from melting and pouring and the aluminum from smelting and casting. ese are now required reporting requirements to import these products into the United States. Collecting that information means coming up with a process for sharing that data, which is still being worked out, but companies are starting to come up with a more uniform process. Johnson: That seems particularly complex when you put it like that. Manufacturers importing those big ingots of smelted alumi- num, for example, have to track where and how much of each ingot ends up in a con- sumer product. That's one heck of a supply chain challenge. Absolutely. It's not something we did before. You need documentation to trace that out. For steel, you would need a test certificate from the steel mill showing where the steel was melted and poured. Suppliers are asking those mills to add that information to the mill test certif- icate, which the supplier would then receive and report to their customer. Implementing those processes needs to happen now, but complying with all this is a large administrative burden. It takes time and resources, so the industry is grappling with it. Johnson: Copper is adjacent to steel, and aluminum and important to EMS providers and PCBs. How does it fit in the current tariff situation? e government has launched an investiga- tion into copper products, under section 232, which allows it to investigate whether imports would threaten national security. at was the basis of the steel and aluminum tariffs. Now there is also an investigation into cop- per. I believe the comment period for that has already ended. We're waiting on the Depart- ment of Commerce (DOC) to issue its findings. at report will include whether those copper imports are threatening national security, and any products that should be within the scope of potential remedial actions. ose remedies may include tariffs, among other things. e government has the power to take a range of actions to address any national security con- cerns if the DOC finds they exist. LaRont: In your experience, how long will it take for the report findings to be released? We expect the DOC's copper investigation report by Dec. 8. James Kim