Question: In the recent CSMS guidance on MHDVs & MHDVPs there is a section labeled “Not Subject to Certain Additional Duties”. In this section the provision exemption code 9903.94.06 is listed and the way I interpret the verbiage the CSMS message indicates that if 9903.94.06 is reported then the importer is exempt from Section 232 […]
Question: When the information is not provided what are other importers doing to calculate % weight content of aluminum, steel, and copper Section 232 imports? Any methodology or logic you can share would be appreciated? Thanks Answer 1: You are expected to back up the percentage value and weight with something factual. If “not provided”, […]
Question: I’m not sure if anyone else in the trade community has experienced this issue and can provide guidance. We import power banks for charging small electronic devices like cell phones. Our power banks are classified as 8507.60.0020 as per several CROSS rulings. This HTS subheading (8507.60) happens to be listed on the Section 232 […]
Question: Has anyone seen guidance on section 232 requirements for alloys? For example, Zamak 3, which is 96% zinc and 4% aluminum. Product HTS is 8302.41.6080 which is flagged for aluminum. Answer 1: There is no formal guidance, except that all standard entry considerations apply. Just like normal products, the 232 programs are evaluated on […]
Question: We import Halloween decorations that are either 100% made of metal or partially metal. Per commercial invoice, the metal is iron. We have classified some items in chapter 73 as articles of iron or steel. Do we still need to pay for 232 tariff under current situation, even it is not steel, but is […]
Question: When importing Slit Coil Aluminum, a non-derivative product, do reciprocal tariffs apply to the non-aluminum portion of the import value, i.e. the value-add portion of the value? Answer 1: When importing slit coil aluminum, the reciprocal tariffs apply to the aluminum content of the product, not to the non-aluminum “value-add” portion. In other words, […]
Question: My company is beginning to formalize our process to solicit suppliers for section 232 information. We created a form and would like input to ensure we are capturing all the information needed to file the entry. The form includes the supplier’s information, product information for each category (aluminum, steel, copper) including part number, HTS […]
Question: Is the Country of Smelt & Cast and/or Country of Melt & Pour required for all aluminum or steel components included (including screws, bolts, springs, etc.) within a kit and/or derivative item or just the essential aluminum/steel components of that kit and/or derivative item? The CSMS Guidance under CSMS # 55438432 indicates that […]
Question: We are seeking your assistance in determining whether our imported product is subject to Section 232 duties on steel. The item in question is a completely electronically controlled puller-tensioner for one rope, featuring two bull wheels (Ø 1500 mm), a groove diameter of 45 mm, and a maximum pulling and tensioning force of 25 […]
Question: As per the new requirements for derivative steel/aluminum articles, if separated on the commercial invoice, could the cost for labor, overhead, and profit be deducted from the value of the steel/aluminum articles in order to reduce the amount paid for tariffs? Answer 1: Yes, that is what we believe, although I am not aware […]
Question: We use specialized steel crates to import products into the U.S. For what it’s worth, we collapse them and return them to be used again. Registering them as instruments of international traffic hasn’t been worth it, so we’ve always treated them as packing and, therefore, dutiable at the product’s duty rate. Would steel packing […]
Question: Would the the new steel tariffs be on top of existing Section 301 duty and the new 10% China duty? So if you had a Chinese steel item with 25% 301 duty, then you would add the 25% new steel duty and the new 10% China duty for a total duty rate of 60%? […]
