Imports Excluded from Section 232 Duties –
Here’s How to File

November 8, 2018

Today CBP published a memo (CSMS# 18-00663) outlining how importers of steel and aluminum articles that have been granted an exclusion from the Section 232 duties should file these imports.

Importers must first request an exclusion from the Section 232 duties for their steel or aluminum articles from the Department of Commerce (Commerce). In the March 19 and September 11, 2018 issues of the Federal Register, Commerce published the process importers should follow to request exclusions from the Section 232 duties on certain aluminum and steel articles. (See our April 11, 2018 newsletter for further information on requesting an exclusion.)

First Step After Receiving the Approved Product Exclusion

Once the importer receives the approved product exclusion from Commerce, an email must be sent to CBP at listing:

  • The company name for the importer of record listed in the approved exclusion,
  • The company address for the importer of record listed in the approved exclusion,
  • The importer of record number for the importer of the record listed in the approved exclusion, and
  • The associated product exclusion number.

For approved quota exclusions, include as a cc on the above email. Do not submit this email until Commerce has approved the product exclusion.

CBP needs the information from the email to activate the approved product exclusion number in ACE so that entries can be filed with this product exclusion number. The information must be provided to CBP before a filer submits entries with that exclusion number to CBP. Similarly, for quota exclusions, CBP must activate the product exclusion number in ACE before any quota exemption can be processed and the goods subject to quota exemption can be released.

CBP activates approved product exclusion numbers in ACE on a weekly basis. In most circumstances, CBP will activate by close of business Thursday any product exclusion numbers where the informational email described above has been submitted to by end of business Monday of that week.

How to Submit Entries Using Product Exclusion Numbers

Importers and filers importing products granted an exclusion should submit the product exclusion number based on the last six digits of the product exclusion docket number at The product exclusion number should be reported 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 articles: ALUXXXXXX

XXXXXX represent the last six digits of the docket number. Do not include spaces or special characters, such as hyphens, in the six digits. Below is an example:

If a steel exclusion is granted under product exclusion docket number BIS-2018-0009-9002, the importer/filer should submit the exclusion number STL099002 (i.e. STL plus the last six digits of the docket number).

Do not submit the corresponding Chapter 99 HTS number for the Section 232 duties when the product exclusion number is submitted.

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

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

Mill certificates must still be submitted as required by 19 CFR 141.89 for steel articles.

Additional Information

Duty exclusions granted by Commerce are retroactive on imports to the date the request for exclusion was accepted (date received) by Commerce. See Presidential Proclamations 9776 and 9777, August 29, 2018.

Refunds for previous imports of duty-excluded products granted by Commerce may be obtained by filing a PSC and providing the product exclusion number in the Importer Additional Declaration Field. If the entry has already liquidated, importers may protest the liquidation.

Once products are excluded from the Section 232 measures, importers may claim Generalized System of Preferences (GSP) or African Growth and Opportunity Act (AGOA) duty preferences on GSP and AGOA-eligible goods. Duty refunds for previously entered goods subject to Section 232 exclusion and GSP or AGOA eligible can be obtained via the PSC or protest process (depending on the entry’s liquidation status).

Information on submitting a PSC can be found in Section 11 of the ACE Entry Summary Business Rules and Process Document.

For further information or questions about this or other customs issues, contact George R. Tuttle, III at 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.

Copyright © 2018 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 the use of such information.




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