More CBP Guidance for Filing Absolute Quota Steel and Aluminum Product Relief


November 13, 2018

In CSMS #18-000671, published 11/13/2018, CBP provides more guidance for the entry filing of imports of steel mill articles and aluminum products granted relief under Section 232 of the Trade Expansion Act of 1962 from the absolute quotas established by the Secretary of Commerce, and paragraphs (1) and (2) of Presidential Proclamation 9777.

According to Customs, before filing entries in ACE, importers or filers must submit a copy of the approved Department of Commerce (Commerce) quota product exclusion with the approved importer of record number to traderemedy@dhs.gov with a courtesy copy to the Quota and Agriculture Branch at HQQuota@cpb.dhs.gov.

CBP must receive and activate the product exclusion number before any quota exemption can be processed and goods subject to the quota exemption can be released.

Only products from the importer(s) designated in the product exclusion approved by Commerce are eligible for the exclusion from the Section 232 measures.

Entry Filing Instructions If Quota Amount Is Still Available

If quota amount is still available under the absolute quota category applicable under which the import is classified, use the filing procedures described below.

Classification

In addition to reporting the regular Chapters 72 and 73 HTS classifications for the imported merchandise, importers should report the following HTS classification for imported merchandise subject to the relief:

  • 9903.80.60 – Steel Mill or Aluminum Articles non-expedited quota approval, or
  • 9903.80.61 – Steel Mill Articles expedited quota approval.

Do NOT submit any other HTS, including any other Chapter 99 HTS.

Quota Entry Types should be used (i.e. entry types, 02, 06, 07, 23, 32 or 38).

Entered Value Information

The entered value of the imported merchandise should be reported on the appropriate Chapter 1-97 HTS classification. The exception to this is for Chapter 98 reporting provisions the may require the entered value to reported differently. Refer to the “HTS Sequence” instructions in CSMS # 18-000624. (See our previous newsletter on multiple HTS filing procedures.)

Product Exclusion Number Information

The filer must report the product exclusion number in the importer additional declaration field (54 record) of the entry summary data using the following format:

  • For excluded steel mill articles = STLXXXXXX
  • For excluded aluminum products = ALUXXXXXX

XXXXXX represents the last six digits of the Regulations.gov approval number. Do not include spaces or special characters such as hyphens.

Example: If a steel exclusion is granted under product exclusion docket number BIS-2018-009-9002, the importer/filer should submit the exclusion number STL099002 (i.e. STL plus the last six digits of the docket number).

Further guidance can be found under the Importer’s Additional Declaration Detail (Input 54-Record) of the CBP and Trade Automated Interfaces Requirements (CATAIR) Manual.

Entry Filing Instructions If the Quota Amount Has Filled

If the quota amount has filled under the absolute quota category under with the import is classified, the importer should use the procedures described below when filing.

In addition to reporting the regular Chapters 72 and 73 of the HTS classification for the imported merchandise, filers should report the following HTS classification for imported merchandise subject to the relief:

  • 9903.80.60 – Steel Mill or Aluminum Articles non-expedited quota approval, or
  • 9903.80.61 – Steel Mill Articles expedited quota approval.

Do NOT submit any other HTS, including any other Chapter 99 HTS.

Quota Entry Types should be used (i.e. entry types, 02, 06, 07, 23, 32 or 38).

For further information or questions about this or other customs issues, contact George R. Tuttle, III at geo@tuttlelaw.com or at (415) 986-8780.

George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in the San Francisco Bay Area.

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.

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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 the use of such information.

 

 

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