Question: Because TIB’s avoid an “entry for consumption,” they are exempt from Section 232, right?(Not exempt from potential duty liability, though. Must post a bond for the entire amount, inc. 232)? Answer 1: Yes, but I am not certain that “exempt” is the correct wording. See CBP’s FAQ’s on section 232 duties. https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel-faqs Answered by: […]
Question: Is this accurate for Section 232 derivatives HTS numbers: Steel: We are permitted to enter Unknown for country of melt and pour provided we’re willing to pay 50% of the entire value of the good. Aluminum: We are permitted to enter Unknown for country of smelt and cast provided we’re willing to pay 200% […]
Question: Has anyone heard of stacking Section 301 Tariffs with other 301 tariffs? If so, has US Customs provided guidance outside of the stacking guidance on 232. Our article of China, product is listed on the good old 4A list at 7.5% (9903.88.15), but also on the 301 25% extended list (9903.91.06 effective Jan 1, […]
Question: Just curious if the vast and unpaid research department known as ICPA members has an opinion on this question. And, of course, what is that opinion?When an imported item is classified with an HTS subject to 232 duties based on the steel content, and the item has no steel content, but has iron content, […]
Question: We import pump bottles which are filled with hair products and cosmetics. Do we need to break out the cost and % of steel of the spring in the pump on the commercial invoice?Our broker is telling us no; we don’t need to but would prefer to confirm with the group.We import the pumps […]
Question: Today, Oct 7, the next round of Sect 232 Inclusion requests was published. Is there a presumption of approval, or of denial? Answer 1: Based off of the August list, it’s a presumption of approval. The only items denied on that list were those that had other open AD/CVD or 232 investigations into the […]
Question: We have a derivative product that is subject to the aluminum Sec 232 tariffs. As of the June 3rd announcement, the non-metal content is no longer exempt from reciprocal tariffs, and the importer may split the metal and non-metal content into two lines.If the importer cannot compliantly split the content into two lines because […]
Question: CBP has published: The value of the copper/steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement The value of the XXX content is the total price paid or payable for that content, which is: The total payment made/to be made for the copper content by the buyer to, […]
Question: Currently we are manufacturing an item in MX where the COO is MX, HTS code is 7616.99.5190, country of smelt is CA. We are looking to source aluminum from the UK, but when I run the tariff simulator with COO MX for 100% aluminum HTS 7616.99.5190, country of smelt UK, the Section 232 is […]
Question: If importing a steel derivative article, and the product comes in a cardboard packaging which is built into the cost of the good, is it reasonable to assume that this cardboard packaging is not subject to the 232 tariff? Answer 1: I believe the cardboard packaging will be subject to the Section 232 tariff, […]
Question: What if the HTS flags for both Sect 232 steel derivatives AND Sect 232 aluminum derivatives AND we can’t separate out the weight and value of the metals? Would 50% then apply to the whole value twice, so 100%? (And yes, I’ve read the FAQs so I’m open to the fact I may have […]
Question: Greetings, What is the tariff percentage on steel when importing under country of melt and pour “unknown”. We have found regulations reference aluminum but not steel. We see either 50% or 200% which is a big swing. Thanks! Answer 1: These are completely separate programs, even though they are often talked about together. While […]
