SPOTLIGHT NEWSLETTER

Updates on Sec 232 Duties on Certain Steel & Aluminum Products

Below please find updates involving the “232” duties that the U.S. is now applying to certain imported steel & aluminum products*.

Canada, Mexico and E.U. Origin Goods Now Subject to 232 Duties

On March 23, the U.S. instituted additional duties on certain steel and aluminum products.  At that time, certain countries were granted a temporary exemption from the duties until May 1, which was later extended until June 1.

Please note that, per Presidential Proclamations, the exemptions for Canada, Mexico, and the European Union countries has not been further extended and subject goods imported from those countries will be assessed the 232 duties effective with goods entered on or after June 1, 2018.  

Importers of products that will be subject to the above additional duties should take steps to prepare, including:

  • Evaluate your immediate and potential duty exposure for the tariffs described above.
  • Ensure your Customs bond amount is adequate to cover the additional duty liability (U.S. Customs or your surety may mandate this to you).
  • Provide your Customs broker with clear instructions to ensure the compliant application of the additional duties on your Customs entries.
  • Make the necessary arrangements for your ability to pay the duties to Customs in association with your Customs entries (may involve setting up a direct ACH account with Customs or specific arrangements with your broker).
  • Review to potentially apply with the U.S. Department of Commerce (DOC) for granting of product exclusions if they meet the prerequisites.
  • Confirm that any articles falling in the affected HTS provisions are correctly classified.

Steel from South Korea, Argentina and Brazil are exempt from the 232 duties and will instead be subject to import quotas. Steel from Australia also remains exempt from the 232 duties. Aluminum from Argentina and Australia remain exempt from the 232 duties.  

  1. May 31, 2018 Presidential proclamation on steel: https://www.whitehouse.gov/presidential-actions/presidential-proclamation-adjusting-imports-steel-united-states-4/
  2. May 31, 2018 Presidential proclamation on aluminum: https://www.whitehouse.gov/presidential-actions/presidential-proclamation-adjusting-imports-aluminum-united-states-4/
  3. U.S. Customs message on latest changes to 232 duties: https://csms.cbp.gov/viewmssg.asp?Recid=23571&page=&srch_argv=18-000372&srchtype=all&btype=&sortby=&sby=
  4.  *See DHL’s Spotlight on the initiation of the 232 duties: https://www.logistics.dhl/us-en/home/our-divisions/global-forwarding/forwarding-insights/spotlight-newsletters/spotlight-newsletter-03142018.html

Claiming Product Specific Exclusions from 232 Duties

A process has been established to allow parties to petition the U.S. DOC to have specific products be excluded from assessment of the 232 duties.  Products which are not produced in the U.S. in a sufficient and reasonably available amount or of a satisfactory quality may be eligible for exclusion. Only U.S. parties may file such petitions.

Parties who receive an approval for exclusion from the 232 duties will receive an assigned exclusion number. Importers who wish to apply the exclusion on their importations must provide specific instructions and the exclusion number to their Customs broker so it may be input into the Custom entry.      

Information on the process to file for product exclusions with the DOC may be found at:


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