The Commercial Customs Operations Advisory Committee submitted to U.S. Customs and Border Protection at a Jan. 14 meeting the following recommendations regarding the implementation of Section 232 tariffs.
- CBP should create clear and easy-to-understand Section 232 tariff guidance, including visuals, decisions trees, flowcharts, and hyperlinks, to make the information more accessible to all importers to support valuation methodology and to clarify more generally the type and nature of documentation required to support a Section 232 tariff claim.
- CBP should recognize, and allow importers to utilize, publicly-available commodity pricing as one of the means for determining and declaring the value of metal included in steel, aluminum, and copper products that are subject to Section 232 tariffs on the value of the metal content.
- With respect to additional inclusions on lists of goods subject to Section 232 tariffs, CBP should collaborate with the Bureau of Industry and Security to clarify what component or article specifically is covered by the inclusion the same way that BIS detailed the type of components or articles covered by the section 232 steel and aluminum tariff exclusions issued in prior years.
- Section 232 tariff inclusions should not be implemented until at least two weeks from the date of publication in the Federal Register.
- CBP should exempt in-transit cargo such that goods already loaded on a conveyance on or before the date tariffs are implemented would be exempt.
- CBP should establish a working threshold for a nominal value to deem a derivative product as insignificant for a Section 232 tariff claim and create a disclaim option.
- CBP should allow importers to declare “other than Russia” origin of aluminum when they are unable to determine the exact single country of origin but can confirm that the aluminum is not of Russian origin.
- CBP should confirm with all ports and Centers of Excellence and Expertise that the Trade Information Notice is to be used as the primary means of communication with the trade.
CBP informed COAC members last summer that it was bringing all existing COAC subcommittees and workgroups to a close and would restructure them to align with priorities under President Trump’s America First Trade Policy. CBP said it was focused on three tenets of that policy: “national security is paramount; prioritize protecting domestic industry and rebuilding its industrial and production capabilities; and close revenue and enforcement gaps from unfair trade practices that undermine national security and/or disadvantage domestic industry.”
However, no information appears to have yet been made available about what the COAC restructuring might look like or what specific issues COAC members might be tasked with addressing.
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