Department of Commerce Proposes New
Aluminum Import Licensing Program

May 7, 2020

In a Federal Register notice published 4/29/2020 (85 FR 23748), the Department of Commerce (Commerce) issued a proposed rule to establish an Aluminum Import Monitoring and Analysis (AIM) system similar to the Steel Import Monitoring and Analysis System (SIMA) that has been in place since 2005.

The Aluminum Import Monitoring program would require importers of aluminum to submit information via an online portal to obtain an automatically issued license and then submit the license number with the entry summary documentation.

Comments on the proposed system must be submitted by 5 pm eastern time, May 29, 2020.

AIM will automatically grant import licenses that will be required to import covered aluminum products (including all aluminum products currently subject to Sections 232 duties). However, as the licenses will be granted prior to submission of the entry summary data, AIM will function as an early warning system – yielding public data 5-6 weeks prior to import statistics released by Census.

The Nuts and Bolts of AIM

The license application of AIM will be in 3 basic parts:

  1. An online registration system for aluminum importers;
  2. An automatic aluminum license issuance system; and
  3. An import monitoring website.

The first step for an importer (or the importer’s agent or customs broker) will be to register with Commerce and be assigned a username. The username will be required in order to access the aluminum import license issuance system.

After obtaining a username, the importer, importer’s agent or customs broker will then apply on-line for the import license by providing basic transaction information to obtain a license for the specific aluminum import transaction. The basic information will include the following:

  1. Filer company name and address;
  2. Filer contact name, phone number, fax number and email address;
  3. Entry type;
  4. Importer name;
  5. Exporter name;
  6. Manufacturer name (filer may state “unknown”);
  7. Country of origin;
  8. Country of exportation;
  9. Expected date of export;
  10. Expected date of import;
  11. Expected port of entry;
  12. Current HTS number (from Chapters 76);
  13. Country where aluminum was smelted and poured;
  14. Quantity (in KG) and
  15. Customs value (U.S. $).

Upon completion and submission of the form, the aluminum import license number will appear on the screen and the user will have the option of printing the license form with the license number.

The license number will be required on every entry summary for aluminum products covered by the licensing requirement. Multiple products in the same entry may be covered by the same license if certain information is the same. If, however, the information differs between aluminum products in the same entry, multiple licenses will be required.

A copy of the SIMA form that is similar to the proposed aluminum import license form can be viewed on Commerce’s website.

Informal Entries, Low-Value Aluminum Entries and FTZ Entries

An import license will not be required for informal entries of aluminum products (such as merchandise valued at less than $2,500). For shipments containing less than $5,000 worth of aluminum, applicants can apply for a reusable Low-Value License (see 19CFR 360.103(f)).

Commerce proposes to require a license for aluminum shipped into a U.S. FTZ, but since a CBP entry number is not available for an FTZ shipment, the license will not require a CBP entry number. As under SIMA, a separate license will not be required upon withdrawal from the FTZ.

Licenses Valid for 75 Days

AIM licenses may be applied for up to 60 days prior to the expected date of importation through the date of filing the entry summary. Additionally, “import license that were valid on the date of importation but expired prior to the filing of entry summary data will be accepted,” Commerce stated in its proposal.

License Recordkeeping

There is no requirement to present physical copies of the license forms at the time of entry summary, but copies will need to be maintained in accordance with Customs’ normal requirements.

Publication of License Data

Commerce proposes creating a standalone aluminum import monitoring website (part 3 of the AIM system discussed above). Aggregate information will be reported on a monthly basis by country of origin, country of smelt and pour, and aluminum product category. The information will include import quantity (metric tons), import Customs value (USD) and average unit value (dollars per metric ton). Historic data will also be available. Information such as the names of importers, exporters and manufacturers will be considered business proprietary information and will not be released to the public.  For more information on Commerce’s proposed website content see 85 FR 23748.

Commerce has stated that it will try to incorporate any changes to the aluminum import monitoring website that are feasible based on the comments received from the import community.

If you have questions about these or other Customs matters, contact George R. Tuttle, III at or at 415-254-5986.


The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence and may not be considered as such.

Copyright © 2020 by Tuttle Law Offices. 
All rights reserved. 

Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from



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