Thursday, March 16, 2023
ADDITIONAL REQUIREMENTS FOR SECTION 232
ALUMINUM AND ALUMINUM DERIVATIVE
ALUMINUM AND ALUMINUM DERIVATIVE
On Friday, March 10, Customs and Border Protection (CBP) issued updated guidance on the new requirements for reporting the countries of smelt and cast for imports of aluminum and aluminum derivative products. This reporting will be required from all countries of origin. Click here to read the CSMS.
Beginning on March 10, 2023, aluminum articles that are the product of Russia and derivative aluminum articles that are the product of Russia will be subject to a 200 percent ad valorem tariff.
Effective April 10, 2023, any imports of aluminum articles or aluminum derivative articles where any amount of the primary aluminum used in the manufacture of the aluminum articles is smelted in Russia or the aluminum articles are cast in Russia, will be subject to a 200 percent ad valorem duty rate.
Now is the time for importers to review their HTS databases for the required reporting of country information for aluminum and aluminum derivative products. FHK will prepare a form to assist in gathering the required information to submit to CBP.
1. Primary Country of Smelt
Report the country where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
2. Secondary Country of Smelt
Report the country where the second largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
If Russia is not the country reported for the primary country of smelt, and any primary aluminum used in the manufacture of the product was smelted in Russia, report the ISO code for Russia as the secondary country of smelt.
Products of the U.S. are not covered by the countries of smelt and cast reporting requirements. Until further notice, for products of the U.S., filers may report “N/A” for the countries of smelt, and U.S. for country of cast.
3. Country of Cast
Report the country where the aluminum (with or without alloying elements) was last liquified by heat and cast into a solid state. The final solid state can take the form of either a semi-finished product (slab, billets or ingots) or a finished aluminum product.
Aluminum articles:
i) unwrought aluminum provided for in heading 7601:
(ii) bars, rods and profiles provided for in heading 7604; wire provided for in heading 7605;
(iii) plates, sheets and strip provided for in heading 7606; foil provided for in heading 7607;
(iv) tubes, pipes and tube or pipe fittings provided for in heading 7608 and 7609;
(v) castings and forgings of aluminum provided for in subheading 7616.99.51.
Note: Even if your company imports raw aluminum, these new reporting requirements also include HTS Subheading 7616.99.51 which covers other articles of aluminum. Many aluminum goods are classified in that subheading so be aware.
Aluminum derivatives articles:
(A) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.10.50);
(B) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing comprising electrical conductors, not fitted with fittings or made up into articles (described in subheading 7614.90.20);
(C) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing not comprising electrical conductors, not fitted with fittings or made up into articles (described in subheading 7614.90.40);
(D) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.90.50);
(E) bumper stampings of aluminum, the foregoing comprising parts and accessories of the motor vehicles of heading 8701 to 8705 (described in subheading 8708.10.30); and
(F) body stampings of aluminum, for tractors suitable for agricultural use (described in subheading 8708.29.21).
Beginning on March 10, 2023, aluminum articles that are the product of Russia and derivative aluminum articles that are the product of Russia will be subject to a 200 percent ad valorem tariff.
Effective April 10, 2023, any imports of aluminum articles or aluminum derivative articles where any amount of the primary aluminum used in the manufacture of the aluminum articles is smelted in Russia or the aluminum articles are cast in Russia, will be subject to a 200 percent ad valorem duty rate.
Now is the time for importers to review their HTS databases for the required reporting of country information for aluminum and aluminum derivative products. FHK will prepare a form to assist in gathering the required information to submit to CBP.
1. Primary Country of Smelt
Report the country where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
2. Secondary Country of Smelt
Report the country where the second largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
If Russia is not the country reported for the primary country of smelt, and any primary aluminum used in the manufacture of the product was smelted in Russia, report the ISO code for Russia as the secondary country of smelt.
Products of the U.S. are not covered by the countries of smelt and cast reporting requirements. Until further notice, for products of the U.S., filers may report “N/A” for the countries of smelt, and U.S. for country of cast.
3. Country of Cast
Report the country where the aluminum (with or without alloying elements) was last liquified by heat and cast into a solid state. The final solid state can take the form of either a semi-finished product (slab, billets or ingots) or a finished aluminum product.
Aluminum articles:
i) unwrought aluminum provided for in heading 7601:
(ii) bars, rods and profiles provided for in heading 7604; wire provided for in heading 7605;
(iii) plates, sheets and strip provided for in heading 7606; foil provided for in heading 7607;
(iv) tubes, pipes and tube or pipe fittings provided for in heading 7608 and 7609;
(v) castings and forgings of aluminum provided for in subheading 7616.99.51.
Note: Even if your company imports raw aluminum, these new reporting requirements also include HTS Subheading 7616.99.51 which covers other articles of aluminum. Many aluminum goods are classified in that subheading so be aware.
Aluminum derivatives articles:
(A) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.10.50);
(B) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing comprising electrical conductors, not fitted with fittings or made up into articles (described in subheading 7614.90.20);
(C) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing not comprising electrical conductors, not fitted with fittings or made up into articles (described in subheading 7614.90.40);
(D) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.90.50);
(E) bumper stampings of aluminum, the foregoing comprising parts and accessories of the motor vehicles of heading 8701 to 8705 (described in subheading 8708.10.30); and
(F) body stampings of aluminum, for tractors suitable for agricultural use (described in subheading 8708.29.21).
| section_232_aluminum_smelt_and_cast_requirements.pdf |
Be sure to contact us if you have any questions about this or any other trade matter.
