News & Press

Mar
26
2018

Updates Regarding Implementation of the Section 232 Tariffs on Steel and Aluminum

In CSMS #18-000240 released last week, CBP provided background information on recent Presidential Proclamations and duty requirements regarding the additional duty on imports of steel and aluminum under Section 232 of the Trade Expansion Act of 1962. The duty requirements of goods entered, or withdrawn from warehouse for consumption, are effective as of last Friday, March 23, 2018.

 

Beginning March 23 and running through April 30, all countries of origin except for Canada, Mexico, Australia, Argentina, South Korea, Brazil and member countries of the European Union (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom) will be subject to the additional duties on steel and aluminum imports. By May 1, 2018, this will include all countries. In a statement released by the White House, President Trump “will decide by May whether to continue to exempt these countries from the tariffs, based on the status of the discussions.”

 

CBP has included the following instructions to assist filers.

 

  • For steel products, in addition to reporting the regular Chapters 72 & 73 of the Harmonized Tariff Schedule (HTS) classification for the imported merchandise, importers shall report the following HTS classification for imported merchandise subject to the additional duty:

 

9903.80.01 (25 percent ad valorem additional duty for steel mill products)

 

  • For aluminum products, in addition to reporting the regular Chapter 76 of the HTS classification for the imported merchandise, importers shall report the following HTS classification for imported merchandise subject to the additional duty:

9903.85.01 (10 percent ad valorem additional duty for aluminum products)

 

Additionally, members of the Customs Committee participated in a telephone conference with senior CBP officials last week to clarify several issues surrounding the implementation of the tariffs on steel and aluminum imports. CBP stated the following:
We are aware that there are entries of targeted products which are on hold and were filed without requesting that the date of arrival be deemed the date of entry.

 

CBP Headquarters has agreed to review these entries and determine whether the date of arrival may be deemed the date of entry even though the entry will be released after the effective date of the Section 232 orders.

 

Also, a question was raised with regard to the date of entry for shipments moving in-bond under an IT. Whereas we had previously believed that the date of entry was the date that the IT was initiated, CBP has suggested that the date of entry may be the date that the entry summary is filed. While CBP has agreed to research the issue further, in light of the impending deadline, members should consider filing summaries on these transactions immediately.

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