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This article applies to:

  • Product: ONESOURCE Global Trade

Adjusting imports of steel into the United States

Date of publication: October 31, 2024

Importer’s additional declaration type 08 in the automated commercial environment

References:

Overview

This document provides a detailed overview of the new CBP reporting requirements for steel melt and pour country, effective
November 21st, 2024 (Subject to Change)
. These requirements stem from Presidential Proclamation 10783, which adjusts the Section 232 tariffs on steel imports from Mexico and mandates the collection of melt and pour country information for all steel imports.

Key changes

  • 25% Tariff on Mexican Steel
    : Effective July 10, 2024, a 25% ad valorem tariff is imposed on steel articles and derivative steel articles that are products of Mexico but melted and poured in a country other than Mexico, Canada, or the United States.
  • Melt and Pour Reporting
    : Importers must now report the country where the steel was originally melted and poured for all primary and derivative steel imports.
  • New 54-Record, Type 08
    : A new Importer’s Additional Declaration Type Code 08 (Steel Melt and Pour Country Detail) is introduced on the 54-record in ACE to capture this information.

Products covered

Per Proclamations 9705 and 9980, and Chapter 99 of the HTSUS, the following steel articles and derivative steel articles are subject to Section 232 measures, and are covered by the melt and pour reporting requirements:
  • Primary Steel articles are defined at the HTSUS 6-digit level as 7206.10 through 7216.50, 7216.99 through 7301.10, 7302.10, 7302.40 through 7302.90, and 7304.10 through 7306.90, including any subsequent revisions to these HTSUS classifications.
  • Derivative iron steel products:
    • (A) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in powder-actuated hand tools, threaded (described in subheading 7317.00.30); and
    • (B) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505, 7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65;
    • (C) bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30); and
    • (D) body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).

Implementation

  • Reporting Requirement Effective Date
    : November 21st, 2024 (
    Subject to Change
    ).
  • Reporting Method
    : Importers must use the new 54-record, Type 08 in ACE.
  • Primary Steel
    : Report the 2-character ISO country code where the steel was melted and poured.
  • Derivative Steel
    : Report the 2-character ISO country code or the Applicability Code 'OTH' (Other) if the ISO code is not known. This is only required for products of Mexico.

Key considerations

  • Steel Mill Certificate
    : A steel mill certificate is required for all Mexican steel articles and derivative steel articles, regardless of whether an exemption from the 25% tariff is claimed.
  • Foreign Trade Zones
    : Steel articles and derivative steel articles that are products of Mexico and entered into an FTZ before July 10, 2024, are subject to the provisions of Proclamations 9894 and 9980 upon entry for consumption after July 10, 2024.
  • Exclusions
    : Articles covered by exclusions granted by the Department of Commerce are exempt from the Section 232 duties.

Potential issues

  • Data Collection and Accuracy
    : Ensuring accurate data collection across all stages of the steel supply chain is crucial for compliance.
  • Timelines for Implementation
    : The short timeframe for testing and implementation (between October 22 and November 21) poses a challenge for importers and software providers to adapt their systems.

Recommendations

  • Familiarize yourself with Proclamation 10783 and associated CSMS messages.
  • Maintain proper documentation, including steel mill certificates, to support your declarations.
  • Stay informed about any updates or clarifications issued by CBP.

How to prepare

How to Prepare
Your ONESOURCE Global Trade Management team is closely monitoring regulatory updates.