Sec 232

  • 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 […]

  • Steel/Aluminum Derative costs

    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 […]

  • Is steel packing material subject to Section 232 duties?

    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 […]

  • New Steel tariffs

    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%?  […]

  • Section 232 Exclusions

    Question: Does anyone have an excel file outlining all exclusions past, current, etc in an Excel file they would be willing to provide? I’m a team of one for a large importer and have been asked to quickly pull all this info together. Unfortunately I do not have any prior experience with 232. Any help […]

  • Steel Stampings from Mexico

    Question: Trying to determine if parts we have stamped in Mexico are subject to the 232 provisions. Steel in coils, or flat, imported into Mexico from China is used to stamp parts that are classified in 8302.41, 8302.50, 7326.90. I have read subchapter III of HTS Chapter 99, note 16, and I do not see that these […]

  • Section 232

    Question: Is this listed in the Federal Register, and did it go into effect July 10, 2024? Under one proclamation, a Section 232 tariff of likely 25 percent will be imposed on steel and steel derivative articles imported from Mexico if the steel is melted and poured in a country other than the U.S., Canada, […]

  • Template for Requesting Mill Certifications from Suppliers

    Question: Hello Members – Does anyone have a sample letter template to suppliers they would be willing to share regarding requesting Mill Certifications for previously purchased aluminum and steel products listed in Annex XVII of the EU Regulation 2014/833 and/or subject to U.S. Section 232 (smelt and cast requirements) 19 CFR 360.101? Answer 1: The […]

  • Section 232 Exclusion Amounts Tallied by CBP

    Question: Need clarification on how section 232 KGS exclusion amounts are tallied by CBP please. The BIS approval letter on an exclusion is valid for one year from the date of signing. The exclusion is in effect until the total weight is imported, or until one year from the original approval date on the letter, […]