Sec 232

  • Section 232 PSCs

    Question: Looking for input from anyone who has successfully had a PSC approved for refunds of Sec 232 duties.  We have multiple entries that we paid duty because we were unable to confirm aluminum/steel content at the time of entry. Since then, we have determined many items with no content at all.I know CBP has […]

  • Section 232 derivative values

    Question: Maybe I’m obtuse, but I hear more detailed interpretations, and it never clears up.CBP guidance says, “the value of the steel/aluminum content is the total price paid or payable for that content … Normally, this would be based on the invoice paid by the buyer of the steel/aluminum content to, or for the benefit […]

  • Section 232 duties on US origin products

    Question: Scenario: We import a product that is classified in an HTS that is subject to 232 Aluminum derivative tariffs, and It is US origin under “substantial transformation” rules (meaning, we will declare US origin on the 7501) Do we have to declare any of the aluminum chapter 99 HTS codes on the 7501 Do […]

  • Question regarding CSMS# 66665333 (MHDVs & MHDVPs) and exemption provision 9903.94.06

    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 […]

  • Weights on 232 Imports

    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”, […]

  • Section 232 duties for Auto Parts duties on Li-ion batteries not for cars

    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 […]

  • Section 232 Guidance on Alloys

    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 […]

  • Iron vs steel

    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 […]

  • Reciprocal Tariffs on

    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, […]

  • Section 232 Supplier Solicitation

    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 […]

  • Reporting on Country of Melt & Pour and Country of Smelt & Cast regarding Kit and/or Derivative items

    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 […]

  • Applicability of Section 232 Steel Tariffs for HTS 8479.89.9596

    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 […]