New Section 232 steel and aluminum tariffs are set to go into effect on Saturday, February 8, 2020. The specific lists for steel and aluminum derivative products primarily covers nails, staples, car and tractor parts, and electrical wire, all which have been determined to have seen import surges.
Quota countries got exemptions (for steel: Argentina, Australia, Brazil, Canada, Mexico, South Korea; for aluminum: Argentina, Australia, Canada, Mexico), though Commerce and USTR will monitor imports from these countries for surges.
Exclusion Applications Will Accepted, But Any Exclusion Granted Only Will Apply To Your Company’s Products
There will also be an exclusion process with relief retroactive to the date of its submission. The exclusion applications for Section 232 applications are specific to your company and product. Every company has to apply individually for your own products, unlike the Section 301 exclusion application you cannot use an HTS code that has been excluded for another company, nor can they use your exclusion.
Background
The Trump administration expanded its Section 232 steel and aluminum tariffs to cover certain imported nails, staples, electrical wires and some downstream parts that go into automobiles and tractors, among other products. The tariff hike will take effect on Feb. 8. Link to White House proclamation.
The decision comes almost two years after the administration implemented tariffs on imports of foreign raw steel and aluminum that President Donald Trump said threatened the viability of the domestic industries and therefore threatened U.S. national security.
While imports of aluminum and steel have declined since the Trump administration imposed levies, some derivative products “have significantly increased since the imposition of the tariffs and quotas,” according to Trump’s proclamation.
National security concerns regarding trade fall under Section 232 of the Trade Expansion Act. The original 232 decision of 2018 covered raw metal making and did not include downstream parts, which was a complaint among some domestic makers of parts that go into heavy machinery, automobiles, airplanes and other goods, who worried that importers would avoid the tariffs by simply importing value-added products.
If you are impacted by this change, please contact the MBS Trade Team listed below.
