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Machinery Center
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Laredo, TX
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Machinery Center
This is a reminder to ensure strict compliance with the reporting guidance outlined in CSMS #65236374 and CSMS #65236645 regarding Section 232 duties on steel and aluminum articles and their derivatives. Accurate reporting of steel and aluminum content and quantities is essential to avoid potential errors, under-collection of duties, and enforcement actions by U.S. Customs and Border Protection (CBP).
Key Reporting Requirements:
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Proper Reporting of Steel and Aluminum Content and Quantities:
- For steel and aluminum articles and their derivative products classified in Chapter 73 (steel) and Chapter 76 (aluminum), the applicable Section 232 duty is assessed only on the value of the steel or aluminum content.
- If the value of the steel or aluminum content is unknown or the same as the entered value, report the duty based on the entire entered value and only on one entry line.
- If the steel or aluminum content value is less than the entered value, report the non-steel/aluminum and steel/aluminum content on separate entry summary lines with the appropriate classifications and quantities.
- Avoid duplicating quantities when splitting entry lines for steel/aluminum and non-steel/aluminum content.
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Mandatory Melt, Pour, Smelt, and Cast Reporting Requirements:
- For steel articles, importers must report the country of melt and pour using the International Organization for Standardization (ISO) code. For steel derivatives, report the ISO code where the steel was melted or "OTH" (for other countries).
- For aluminum articles, importers must report the primary country of smelt, secondary country of smelt, or country of most recent cast using the ISO code. Filers must report “Y” for primary country of smelt and/or secondary country of smelt. Aluminum manufactured only from recycled aluminum must be substantiated with manufacturing documents upon request.
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Foreign Trade Zone (FTZ) Entries:
- Steel and aluminum articles and their derivative products entered into a U.S. FTZ must be granted "privileged foreign status" and reported under the applicable HTS classifications.
- Smelt and cast reporting requirements also apply to aluminum goods admitted into a U.S. FTZ and withdrawn for consumption.
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Duties for Aluminum from Russia:
- The 200 percent duty on aluminum products and derivative aluminum products from Russia remains in effect. These duties apply to the entire value of the imported good.
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Application of Reciprocal Tariffs:
- Non-steel/aluminum content of an article reported on a separate line per the instructions above is subject to Reciprocal tariffs under HTS 9903.01.25. Steel/aluminum content subject to Section 232 duties is not subject to Reciprocal tariffs under HTS 9903.01.33.
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Reporting Multiple HTS Numbers:
- For entry summary lines that include multiple HTS numbers, CBP requires that the duty be appropriately associated with the correct HTS. Duties across several required HTS numbers on a given entry summary line must not be combined and cannot be reported on only one HTS within the entry summary line.
CBP expects full compliance from the trade community for accurate reporting and payment of additional duties. Failure to adhere to these guidelines may result in enforcement actions, including documentation reviews, cargo examinations, and other corrective measures.
For questions regarding Section 232 entry filing, please contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov. If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
Thank you for your cooperation in ensuring accurate and compliant reporting practices.
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