On June 4th, the White House issued a Proclamation to increase tariffs under Section 232 for Steel & Aluminum to 50%. In addition, there has been an update to Executive Order (EO) 14289 ‘Addressing Certain Tariffs On Imported Articles’. Under the previous EO, if your goods were subject to multiple tariffs under IEEPA and Section 232, the order of the tariff will dictate which tariff would apply and what would be excluded. Under the amended EO, the order of priority has changed. Please see the link below for further guidance.
The new priority order is:
1) Section 232 Auto/Auto parts
2) Section 232 Aluminum
3) Section 232 Steel
4) IEEPA Canada
5) IEEPA Mexico
Under the new priority order, if your tariff code is listed on the Section 232 Auto parts list, it is imperative to report whether your article is in fact subject to this tariff. If your article is not for use in the automobile industry, or is not an auto part, this must be clearly indicated on your commercial invoice. A statement such as ‘NOT AUTO PARTS’ or ‘NOT FOR USE IN AUTOMOBILES’ would notify your broker as well as U.S. Customs that your article is not subject to duty under Section 232 for Autos/Auto parts. A list of parts subject to duty can be found at the link below.
CSMS # 64916652 – UPDATE to CSMS # 64913145:D GUIDANCE: Import Duties on Certain Automobile Parts
What else changed on June 4th?
Under the new Proclamation issued June 3rd, Section 232 tariffs on Steel and Aluminum will increase from 25% to 50% effective at 12:01am on June 4th. However, imports of steel and aluminum from the United Kingdom will remain at 25% until at least July 9th. A list of tariffs codes subject to Section 232 Steel and Aluminum duty can be found at the links below. Additional information on reporting steel and aluminum content will be forthcoming.
CSMS # 65236374 – UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products