CBP recently issued guidance on melt and pour requirements for certain imported steel articles, implementing President Biden’s July proclamation adjusting imports of steel and aluminum into the United States.
Steel and Aluminum Proclamation Background
On July 10, 2024, President Biden issued two proclamations on adjusting imports of steel and aluminum into the United States. The proclamations increased the section 232 duty rate for both products and adjusted the requirements for avoiding section 232 duties.
The steel proclamation implemented a melt and pour requirement for imports of steel articles that are products of Mexico. It also increases the section 232 duty rate for imports of steel articles and derivative steel articles that are products of Mexico that are melted and poured in a country other than Mexico, Canada, or the United States. If the country of melt and pour is any country other than the U.S., Mexico, or Canada, then the steel articles are subject to an additional 25%.
Effective November 21, 2024, importers are required to report to CBP the country of melt and pour for certain imported steel articles from all countries; and for imported derivative steel articles that are products of Mexico; regardless of whether Section 232 duty treatment, quota treatment, or an exception treatment applies.
CBP Guidance on Steel
The new guidance provides information on codes for reporting the country of smelt, certificates to be submitted via the Automated Commercial Environment (ACE), and advises importers on changes that have been made in ACE.
Reporting Codes & Certificates
The guidance states that when reporting the country of melt and pour, the International Organization for Standardization (ISO) country code where steel was originally melted and poured is mandatory. For imports of derivative steel products, the code is only required for products of Mexico. For derivative steel that are products of Mexico only, the applicability code “OTH” (Other) can be used if an ISO code was not provided in the country of melt and pour field.
A steel mill certificate is required to be submitted via the Document Image System (DIS) in ACE for steel imports in Chapter 72 or headings 7301 to 7307 of the Harmonized Tariff Schedule of the United States (HTSUS).
ACE Updates CATAIR Entry Summary
CBP also notified importers that the ACE CBP and Trade Automated Interface Requirements (CATAIR) Entry Summary Dictionary has been updated to include new declaration type code. The updates were deployed on October 22, 2024.
Looking Ahead
Importers should revisit their policies and procedures governing steel imports to ensure compliance with these requirements. We will continue watching closely for any changes that may occur with the new Administration.
For assistance or for more information on how these changes will impact your business, contact Diaz Trade Law.
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