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 […]
Question: We have an importer client with goods of US origin however the HTS# 8544,60.2000 requires country of smelt and cast. The importer does NOT know the country of smelt and cast at this time of entry. We are entering the goods under HTS# 8544,60.2000. Question: Do we have to claim country of smelt and […]
Question: When we have an HTS that falls under more than one list, do we really have to pay 50% on each list under which it falls? For instance, 8504.33.00 is on both the steel and aluminum lists. We do not currently have the material breakdown for the item we are importing, however, it can’t […]
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: Hello ICPA Community, If a part subject to Section 232 tariff and contains US melt/pour and non-US melt/pour steel content, how is transaction value apportioned to the US and non-US melt/pour: by weight, by value of raw material apportioned with overhead, labor, etc. or any other methodology exist out there? In a simple scenario, […]
Question: What are your thoughts on preparing a fallback estimation technique for section 232? I’m thinking we take some worst-case assumptions that product weight = steel weight, then use a high market price cost estimation. At least if it’s worst-case assumptions, it would be defensible. I’m just thinking that even if we use that it […]
Question: I’m looking to confirm whether CBP will consider the Country of Diffusion or Country of Origin for semiconductors when applying Section 232 tariffs. Any advice or guidance is greatly appreciated. Answer 1: There are several recent very good rulings on this subject. In N350711 (2025) CBP explained: It is the opinion of this office […]
Question: I cannot make heads or tails of the new guidance towards the 232 steel/aluminum/copper duties under the new Japan-US agreement. If there is an entry that has provided a breakdown of percentage for the acquisition cost of the steel, would the remaining commercial value still be subject to the reciprocal duties? Or has the […]
Question: The expanded Section 232 Steel and Aluminum Derivative Requirements include fragrances and cosmetics in chapter 33 and 34. Does this apply to the product only, or do we also need to provide a % breakdown for the packaging as well? Manufacturers seem to be having a difficult time providing the breakdown in general. Answer […]
