CBP adds new information requirements when filing Section 232 Import Entries

U. S. Customs and Border Protection (CBP) has or is adding additional information requirements when filing Entry Summaries for steel and aluminum merchandise covered by Section 232 in support of the Presidential Proclamations regarding products of Mexico. Additional eligibility requirements for exclusion from Section 232 duties were added effective July 10, 2024. For steel, all covered articles must only use steel “melted and poured” in Mexico, Canada or the U. S. to be eligible for the exclusion. For aluminum, the countries of “smelt and cast” must be other than China, Belarus, Iran, or Russia.

Steel
Cargo Systems Messaging Service (CSMS) #62582900 establishes, effective November 21, 2024, a new requirement to disclose the country of melt and pour on the Entry Summary through the Importer’s Additional Declaration Type Code 08 (Steel Melt and Pour Country Detail) on the 54-record. Disclosure is required for steel articles subject to Section 232 from all countries, and for derivative steel products only for products of Mexico.
According to the CSMS message, “Country of melt and pour refers to the original location where the raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. The first solid state can take the form of either a semi-finished product (slab, billets, or ingots) or a finished steel mill product. The location of melt and pour is customarily identified on mill test certificates generated at each stage of the production process and maintained in the ordinary course of business.” Steel mill certificates are required to be submitted as part of the entry for all products in HTSUS Chapter 72 and headings 7301 to 7307. The Message also includes links to the lists of steel articles and of derivative steel products covered.
https://content.govdelivery.com/bulletins/gd/USDHSCBP-3baf074?wgt_ref=USDHSCBP_WIDGET_2

Aluminum
The new requirement to disclose the countries of smelt, secondary smelt, and cast for aluminum and aluminum derivative articles subject to Section 232 that are products of Mexico is implemented on the Entry Summary using the Importer’s Additional Declaration Type Code 07 (Aluminum Smelt and Cast Country Detail). In addition, a Certificate of Analysis must be provided for such articles. Exclusion from Section 232 duties is available only if the smelt and cast countries are other than China, Belarus, Iran, or Russia. These requirements were effective July 10, 2024.CSMS Message # 62063449 also notes that any products where any amount of primary aluminum was smelted or cast in Russia are also subject to 200% duties under the previously announced sanctions on Russia.
https://content.govdelivery.com/bulletins/gd/USDHSCBP-3b30359?wgt_ref=USDHSCBP_WIDGET_2

CSMS Message #55438432 lists the covered aluminum and aluminum derivative products. It also provides definitions of the primary and secondary countries of smelt and cast.
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/34dec60

ITA Import License Requirements
The International Tade Administration of the U. S. Commerce Department requires import licenses for basic steel and aluminum products covered by Section 232 (although not for derivative articles.) While these licenses require melt and pour (steel) and smelt and cast (aluminum) information, CBP only requires a valid license number to be filed with each Customs entry, not a copy of the license itself. CBP does not have automatic access to the melt and pour or smelt and cast information on the license. https://www.trade.gov/us-steel-industry-import-licensinghttps://www.trade.gov/us-aluminum-industry-licensing