CBP Guidance for Imports of Aluminum, Steel and Copper

U.S. Customs and Border Protection has released the following notice regarding the changes to aluminum, steel and copper imports.

If you have any questions, please contact our office.

CSMS # 68855869 - GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States

The purpose of this message is to provide guidance on the implementation of the June 1, 2026, Proclamation, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States.”

BACKGROUND

On April 2, 2026, the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  This proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective April 6, 2026. See 91 FR 18201 and CSMS 68253075.

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending Proclamation 11021, adding new metals derivatives subject to Section 232 duties and reducing the Section 232 duty rates for other derivatives. See 91 FR 34085.

GUIDANCE

This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) on certain steel, aluminum, and copper articles and their derivatives from all countries as provided in Harmonized Tariff Schedule of the United States (HTSUS) headings 9903.82.01 to 9903.82.26.  Separate instructions will be provided on HTSUS headings 9903.82.18 and 9903.82.19 at a later date.

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026:

The following HTSUS classifications will be subject to Section 232 duties under Proclamation 11021, as amended:

3701.30.00

9403.20.0075

9403.20.0082

9403.99.9040

The following HTSUS classifications will be subject to reduced Section 232 duty rates:

8407.90.10 8429.59.10 8701.93.10
8415.10.60 8429.59.50 8701.93.50
8415.10.90 8431.20.00 8701.94.10
8415.81.01 8431.42.00 8701.94.50
8415.82.01 8431.49.90 8701.95.10
8415.90.80 8432.10.00 8701.95.50
8419.81.50 8432.90.00 8703.21.01
8427.10.40 8433.20.00 8705.10.00
8427.10.80 8433.51.00 8705.20.00
8427.20.40 8433.59.00 8706.00.30
8427.20.80 8433.90.50 8708.29.2120
8427.90.00 8479.89.55 8708.29.2130
8429.11.00 8479.89.65 8708.40.30
8429.19.00 8516.29.00 8708.40.60
8429.20.00 8701.10.01 8708.92.10
8429.30.00 8701.30.10 8708.92.60
8429.40.00 8701.30.50 8708.93.15
8429.51.10 8701.91.10 8708.93.30
8429.51.50 8701.91.50 8708.99.23
8429.52.10 8701.92.10 8716.80.10
8429.52.50 8701.92.50 8716.90.10

See the attachment for the Chapter 1 to 97 HTSUS classifications which correspond to each Chapter 99 heading.  All changes listed above are indicated in bold in the attachment.

Except for the changes listed above, for HTSUS 9903.82.01 to 9903.82.19, the additional duties were effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on April 6, 2026.

Headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 were effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on April 6, 2026, and before January 1, 2028.

For HTSUS 9903.82.20 to 9903.82.26, the additional duties will take effect with respect to goods entered for consumption, or withdrawn from warehouse for

consumption, on or after 12:01 a.m. eastern time on June 8, 2026, and before January 1, 2028.

Effective with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on January 1, 2028:

  • the goods covered by headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, and 9903.82.09; and.
  • the goods covered by HTSUS 9903.82.20 to 9903.82.26 will be subject to the duty rates under HTSUS 9903.82.05, 9903.82.06, 9903.82.09, 9903.82.15 and 9903.82.16.

Additional guidance will be provided prior to January 1, 2028.

9903.82.01: Articles provided for in subdivision (c) of U.S. note 16 to this subchapter that do not contain any aluminum, steel, or copper.

0% additional ad valorem rate of duty

9903.82.02: Except as provided for in headings 9903.82.14, 9903.85.67 and 9903.85.68, applies to articles of aluminum, of steel, or of copper and derivative aluminum or steel articles, as provided for in subdivision (c)(i) -(v) of U.S. note 16 to this subchapter.

50% additional ad valorem rate of duty

9903.82.03: Except for articles classifiable in Chapters 72, 73, 74, or 76, articles where the weight of the applicable metal is less than 15 percent of the weight of the imported article, as provided for in subdivision (c) of U.S. note 16 to this subchapter.

0% additional ad valorem rate of duty

When reporting HTSUS 9903.82.03, report the aggregate weight of the applicable metal(s) in kg as a second quantity on the entry summary line.

9903.82.04: Applies to articles of aluminum or of steel and derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(i)-(iv) and (d) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

9903.82.05: Applies to derivative aluminum or steel articles that are the product of the United Kingdom in which at least 95 percent of the aluminum was smelted or most recently cast in the United Kingdom, or in which at least 95 percent of the steel was melted and poured in the United Kingdom as provided for in subdivisions (c)(vi)-(vii) and (d) of U.S. note 16 to this subchapter.

15% additional ad valorem rate of duty

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on June 8, 2026, the threshold for imported products to qualify as made "entirely" from American aluminum, steel, or copper, is modified from 95 percent to 85 percent, as follows:

Headings 9903.82.06, 9903.82.07, 9903.82.08, 9903.82.23 and 9903.82.24 apply to certain articles of copper and derivative aluminum and steel articles provided for in subdivision (c) of this note.

  • For derivative articles provided for in subdivisions (c)(ii), (vi), and (ix), at least 85 percent of the aluminum content of the article must be composed of aluminum that was smelted and cast in the United States.
  • For derivative articles provided for in subdivisions (c)(iv), (vii), (x) and (xi), at least 85 percent of the steel content of the article must be composed of steel that was melted and poured in the United States.
  • For articles provided for in subdivision (c)(viii), at least 85 percent of the copper content of the article must be composed of copper that was smelt and cast in the United States).
  • These requirements are cumulative such that a derivative article in more than one subdivision must satisfy each requirement.

9903.82.06: Except as provided for in headings 9903.82.15 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(ii), (iv), (vi) - (viii), (xi) and (e) of U.S. note 16 to this subchapter.

10% additional ad valorem rate of duty

9903.82.07: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.

For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 10%.

9903.82.08: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided in subdivisions (c)(ix)-(x) and (e) of U.S. note 16 to this subchapter.

For articles for which the applicable column 1 duty rate is 10 percent or higher, no additional duty is due.

9903.82.09: Except as provided for in headings 9903.82.16, 9903.82.20–9903.82.26 and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(vi)-(viii) and (xi) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

9903.82.10: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter

For articles for which the applicable column 1 duty rate is less than 15 percent, the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 15%.

9903.82.11: Except as provided for in headings 9903.82.12, 9903.82.17 and 9903.85.68, applies to derivative aluminum and steel articles, as provided for in subdivision (c)(ix)-(x) and (f) of U.S. note 16 to this subchapter

For articles for which the applicable column 1 duty rate is 15 percent or higher, no additional duty is due.

9903.82.12: Except as provided for in headings 9903.82.17 and 9903.85.68 applies to derivative aluminum and steel articles, the product of any country identified in general note 3(b) (countries subject to the column 2 duty rates in the HTSUS), as provided for in subdivision (c)(ix)-(x) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

9903.82.13: Applies to articles that otherwise meet the criteria of subdivisions (c)(vi)-(viii) and (xi) that are motorcycle parts classifiable in Chapter 84, 85, or 87 for use in the manufacturing of motorcycles in the United States.

0% additional ad valorem rate of duty

9903.82.14: Applies to articles of steel or of copper and derivative steel that are the product of the Russian Federation as provided for in subdivisions (c)(iii)–(v) of U.S. note 16 to this subchapter.

50% additional ad valorem rate of duty

9903.82.15: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(iv), (vii), (viii), (xi) and (e) of U.S. note 16 to this subchapter.

10% additional ad valorem rate of duty

9903.82.16: Applies to articles of copper and derivative steel that are the product of the Russian Federation, as provided for in subdivisions (c)(vii)–(viii) and (xi) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

9903.82.17: Applies to derivative steel articles that are the product of the Russian Federation, as provided for in subdivision (c)(x) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

For headings 9903.82.18 and 9903.18.19, entry filing instructions will be provided at another time.

Headings 9903.82.20 and 9903.82.21:  Apply to derivative steel articles provided for in subdivision (c)(xi) that are the products of Canada and Mexico and eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA).

9903.82.20: Applies to the non-U.S. content of derivative steel articles and to U.S. content that exceeds 40 percent of the value of such derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter.

25% additional ad valorem rate of duty

9903.82.21: Applies to the U.S. content of derivative steel articles as provided in subdivision (j) of U.S. note 16 to this subchapter, except that U.S. content that exceeds 40 percent of the value of such derivative steel articles shall be subject to the rates of duty provided in heading 9903.82.20.

0% additional ad valorem rate of duty

Do not report more than 40 percent of the value of the U.S. content of the good in heading 9903.82.21.

For the purposes of U.S. note 16, U.S. content refers to the value of the article attributable to parts produced in the United States.  The non-U.S. content of the article shall be calculated by subtracting the value of the U.S. content in the article from the total value of the article.

See additional reporting instructions for HTSUS 9903.82.20 and 9903.82.21 below.

9903.82.22: Applies to derivative steel articles the product of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union, as provided for in subdivision (c)(xi) of U.S. note 16 to this subchapter.

15% additional ad valorem rate of duty

Headings 9903.82.23–9903.82.26 apply to parts classifiable in the provisions of subdivision (c)(vi)–(viii) that are in chapters 84, 85, or 87 that will be used exclusively in the manufacturing of  agricultural equipment or fixed industrial equipment provided for in subdivision (c)(ix)−(x) or mobile industrial equipment provided for in subdivision (c)(xi). Headings 9903.82.23–9903.82.26 do not apply to products of any country identified in general note 3(b) (Belarus, Cuba, North Korea, and Russia).

9903.82.23: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.

For articles for which the applicable column 1 duty rate is less than 10 percent, the sum of the column one duty rate and the additional ad valorem rate of duty will be 10%.

9903.82.24: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 10 percent, as provided for in subdivisions (e) and (k) of U.S. note 16 to this subchapter.

For articles for which the applicable column one duty rate is 10 percent or higher, no additional duty is due.

9903.82.25: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 less than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.

15% additional ad valorem rate of duty

9903.82.26: Applies to articles of copper and derivative aluminum and steel articles with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 15 percent, as provided for in subdivisions (f) and (k) of U.S. note 16 to this subchapter.

0% additional ad valorem rate of duty

Reporting Instructions for Applying the Tariff Treatment Under HTSUS 9903.82.20 and 9903.82.21

When claiming treatment under HTSUS 9903.82.20 and 9903.82.21, the non-U.S. content and the U.S. content value of the derivative products must be reported on two lines.

The first line will represent the value of the non-U.S. content and the U.S. content that exceeds 40 percent of the value of such derivative steel articles, while the second line will represent the value of the U.S. content.  Each line should be reported in accordance with the instructions below.

Non-U.S. content, first line:

Report the total quantity of the imported goods

Report the value of the non-U.S. content by subtracting the value of the U.S. content reported under HTSUS 9903.82.21 from the entered value of such derivative articles.

Report the Section 232 duties based on the value such content with HTSUS 9903.82.20.

Report Special Program Indicator (SPI) code “S”

Report Ch. 1-97 HTSUS, same HTSUS must be reported on both lines.

Report country of origin (Canada or Mexico), same country of origin must be reported on both lines.

Report all other applicable duties, such as antidumping and countervailing duties

U.S. content, second line:

Report 0 for quantity.

Report the entered value of the U.S. content, up to 40 percent of the total entered value of the imported goods

Report the 0 duties based on the value of U.S. content with HTSUS 9903.82.21.

Report Special Program Indicator (SPI) code “S”

Report the same Ch. 1-97 HTSUS reported on the first line.

Report the same country of origin reported on the first line.

Report all other applicable duties, such as antidumping and countervailing duties.

Russia Aluminum Duties

All imports of aluminum articles and aluminum derivative articles covered by this Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of these aluminum articles is smelt in Russia, or these aluminum articles are cast in Russia, shall continue to be subject to the 200 percent ad valorem rate of duty under HTSUS heading 9903.85.67 for aluminum products; and heading 9903.85.68 for aluminum derivative products.

Russia aluminum and aluminum derivative products subject to HTSUS headings 9903.85.67 and 9903.85.68 may not be reported under HTSUS 9903.82.03.

Reporting of Countries of Melt and Pour and Smelt and Cast

Continue to report the countries of melt and pour for all subject steel and steel derivative products and the countries of smelt and cast for all subject aluminum and aluminum derivative products.  See, e.g., Cargo System Messaging Service (CSMS) messages 64348411, 64348288, and 65340246 for reporting instructions.

CBP will issue a CSMS to announce when the reporting of the countries of copper smelt and cast will be required and the corresponding functionality is available in ACE for imports of copper products under the following HTSUS classifications:8544.42.10; 8544.42.20; 8544.42.90; and 8544.49.10.

Please note that imports under HTSUS 9903.82.03, 9903.82.13 and 9903.82.21 are not eligible for the Section 122 exemption for Section 232 products under HTSUS 9903.03.06.  See CSMS # 67844987 - Imposing Temporary Section 122 Duties.

For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.

If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.

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by IAB Admin

Trump Administration Announces Major CBP Enforcement Reforms

President Trump has signed an Executive Order directing CBP to strengthen customs enforcement and close perceived gaps in importer compliance.

See the following message from NCBFAA for more details.

President Trump Signs Executive Order to Strengthen CBP Enforcement

President Trump on June 3 signed an Executive Order to straighten the enforcement capabilities of Customs and Border Protection (CBP), with a focus on the importer of record (IOR) and preventing the evasion of customs duties.

“Customs reform is long overdue. Systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes have created opportunities for malign actors to evade Federal law. Examples of noncompliance include undervaluing imports, withholding critical information about IORs and the goods being imported, and avoiding payment of duties through various arrangements and schemes. These actions threaten national security, undermine foreign relations, disadvantage domestic businesses, and harm Americans,” the Executive Order said.

“The United States must strengthen its customs enforcement through comprehensive reform, including through agency action and legislation. Such reform should focus on protecting national security, promoting lawful trade, ensuring the timely collection of duties, modernizing systems and processes, bolstering compliance mechanisms, increasing transparency, and protecting Americans and the domestic economy,” the order added.

The Executive Order states that within the 180 days of the date of this order, the Secretary of Homeland Security shall, pursuant to 19 U.S.C. 66, 1484, 1498, 1623, 1624, and 4320, and any other applicable law, take steps to revise importer eligibility regulations, guidance, and policies consistent with the policy of this order. These revisions shall include:

  • Requiring that an IOR maintain at all times a minimum level of tangible domestic assets, bonding, or both, as determined by CBP to be necessary to ensure compliance with U.S. customs and trade laws, and increasing the minimum required bond coverage for an IOR.
  • Requiring that an IOR be designated and reported to CBP, and that a bond, or sufficient tangible domestic assets, or both, be required, for all formal entries under 19 U.S.C. 1484 and informal entries under regulations promulgated pursuant to 19 U.S.C. 1498.
  • Requiring that an IOR provide to CBP additional data and identification information, including anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures, and any other data that CBP deems necessary.

The Executive Order added that prohibiting the filing of informal entries for foreign IORs puts all IORs on “equal footing and is necessary to treat IORs equally based on their individualized circumstances and in order to protect U.S. revenue and domestic industry, protect American consumers, strengthen national security, and maintain foreign relations.”

The Executive Order further said a foreign IOR: (1) may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP when the foreign IOR has demonstrated that the revenue would be fully protected and that compliance with the laws, regulations, and instructions enforced by CBP would be assured; and (2) be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT), if determined by CBP to be eligible.

“IORs not in “good standing” with CBP shall not be allowed to import into the United States or otherwise conduct activities directly related to the importation of goods, including designating a customs broker to act as IOR on their behalf,” the order added.

President Trump’s order also stated that the DHS Secretary must establish heightened import disclosure and certification requirements, including certifying compliance with critical supply chain requirements like the Countering America’s Adversaries through Sanctions Act (Public Law 115-44), 18 U.S.C 545, and others to be determined by CBP, in consultation with the heads of relevant executive departments and agencies (agencies); disclosing certain foreign tax and global business identifiers; and providing detailed information about the imported good’s supply chain and production methods, such as the manufacturer’s product identifier (e.g., model or style number) or key specifications (e.g., composition, grade, or size).

CBP enforcement and penalties for wrongdoing will be enhanced by the administration through this Executive Order, including enforcing liquidated damages claims against bonds for noncompliance, restricting in-bond utilization, increasing audits, and imposing maximum penalties for customs brokers who fail to conduct due diligence, repeatedly represent noncompliant clients, or fail to cooperate in a timely manner with requests for information by CBP.

In addition, the Executive Order states that enforcement action will be heightened by CBP against imports involving products produced by forced labor, misclassification, undervaluation, and illegal transshipment, including investigations conducted pursuant to the Enforce and Protect Act (Public Law 114-125).

If you have any questions, please contact our office.

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by IAB Admin

Implementation of Taiwan Tariffs

U.S. Customs and Border Protection has released the following notice regarding the change in certain tariffs applicable to products from Taiwan.

CSMS # 68762890 - GUIDANCE: Implementation of Certain Tariff-Related Elements of the Trade and Security Agreement Between the Taipei Economic and Cultural Representative Office and the American Institute in Taiwan

The purpose of this message is to provide guidance on the modification of certain Section 232 tariffs applied to aircraft components, automobile parts and wood products of Taiwan.

BACKGROUND

On May 28, 2026,  the Secretary of Commerce (Secretary) and the United States Trade Representative (USTR) will publish a Federal Register Notice (FRN) “Implementing Certain Tariff-Related Elements of a Trade and Security Agreement Between the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States,” to modify certain Section 232 tariffs applied to certain aircraft components, automobile parts and wood products of Taiwan, effective for goods entered for consumption, or withdrawn from warehouse consumption, on or after 12:01 a.m. eastern time on May 1, 2026.

GUIDANCE

This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) pertaining to imports of certain aircraft components, automobile parts and wood products of Taiwan under headings 9903.94.66, 9903.94.67, 9903.94.68, 9903.94.69, 9903.76.24 and 9903.96.03 of the Harmonized Tariff Schedule of the United States (HTSUS).

The following HTSUS classifications and duty rates are effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time May 1, 2026. To the extent that implementation of this notice requires a refund of duties collected, importers may file a Post Summary Correction to request a duty refund.

Automobile Parts

9903.94.66: For an automobile part that is the product of Taiwan as provided for in subdivisions (g) and (u) of U.S. note 33 to this subchapter, with a Column 1 duty rate equal to or greater than 15 percent ad valorem.

0% additional ad valorem rate of duty

9903.94.67: For an automobile part that is the product of Taiwan as provided for in subdivisions (g) and (u) of U.S. note 33 to this subchapter, with a Column 1 duty rate less than 15 percent ad valorem.

15% additional ad valorem rate of duty

(15% is the combined Column 1 and Section 232 tariff rate)

Self-Certifying Automobile Parts

Applies to parts of passenger vehicles and light trucks (automobiles) that are the product of Taiwan when certified by the importer of record that such parts will be used for automobile production or repair activity in the United States, excluding articles classifiable in chapters 72, 73, or 76; articles classifiable in the provision of subdivision (g) of U.S. note 33; and articles classifiable in the provisions of subdivision (i) of U.S. note 38 to this subchapter.

To certify that such parts will be used for automobile production or repair activity in the United States, and not covered by the exclusions above, report one of the following Chapter 99 HTSUS:

9903.94.68: For an automobile part that is the product of Taiwan as specified in subdivisions (r) and (u) of U.S. note 33 to this subchapter, with a Column 1 duty rate  equal to or greater than 15 percent ad valorem.

0% additional ad valorem rate of duty

9903.94.69: For an automobile part that is the product of Taiwan as specified in subdivisions (r) and (u) of U.S. note 33 to this subchapter, with a Column 1 duty rate less than 15 percent ad valorem.

15% additional ad valorem rate of duty

(15% is the combined Column 1 and Section 232 tariff rate)

Wood products

9903.76.24: For wood products of Taiwan as provided for in subdivisions (d) and (f) of U.S. note 37 of this subchapter.

15% additional ad valorem rate of duty

Changes to Section 232 for Civil Aircraft Components

As provided in heading 9903.96.03, the additional duties imposed by headings 9903.82.02 and 9903.82.04–9903.82.19 (duties on aluminum, copper, and steel derivative products) shall not apply to articles the product of Taiwan that are civil aircraft (all aircraft other than military aircraft and unmanned aircraft) components that otherwise meet the criteria of General Note 6 of HTSUS, and are classifiable in the provisions of the HTSUS listed in the FRN “Implementing Certain Tariff-Related Elements of a Trade and Security Agreement Between the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States,” but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub-column

Continue to report Special Program Indicator “C” to claim the preferential treatment for the column one rate of duty on the articles subject to the Agreement on Trade in Civil Aircraft.

DRAWBACK

Drawback continues to be available, in accordance with applicable regulations in 19 C.F.R. part 190, for eligible claims with respect to the auto parts duties imposed pursuant to Proclamation 10908, as amended, and the wood products duties imposed under Proclamation 10976.

NOT SUBJECT TO CERTAIN ADDITIONAL DUTIES

Entries of automotive parts described in U.S. note 33 subdivision (u) shall not be subject to the additional duties imposed on:

(1) articles of aluminum, of steel, or of copper or derivative aluminum, steel, or copper articles provided for in headings 9903.82.02 and 9903.82.04–9903.82.19.

(2) wood products provided for in headings 9903.76.01, 9903.76.02, 9903.76.03, and 9903.76.24.

For the list of Chapter 1 to 97 HTSUS classifications subject to HTSUS 9903.74.24, see CSMS 66492057 (listed under HTSUS 9903.76.02-9903.76.04).

For the list of Chapter 1 to 97 HTSUS classifications subject to HTSUS 9903.94.66 and 9903.94.67, see CSMS 64913145 (listed under HTSUS 9903.94.05).

For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.

If you have any questions, please contact our office.

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by IAB Admin

IEEPA Tariff Refunds: Preparing for the Commercial Impact

As IEEPA tariff refunds begin reaching importers, companies are now facing a new set of complex commercial, contractual, and compliance decisions that could have significant financial and legal implications.

See the following message from Sidley Austin LLP with key questions you might need to consider to plan ahead.

Now that the IEEPA tariff refunds are starting to flow, it is increasingly important that companies have a plan for how they are going to deal with the associated commercial implications.

If you increased prices because of the tariffs (wholly or in part), are you going to refund some/all of the refunds to your customers? If so, will it be a refund or a credit on future purchases? Are you going to share any of the tariff refund with foreign suppliers who adjusted their prices because of tariffs? If you do, does that create customs valuation issues for past imports? Are you going to seek reimbursement for tariff-related price increases passed on to you by your suppliers? What do your contracts require? What are the commercial realities; do they vary by customer/supplier? What is the risk you will be sued? What can you do to minimize that risk?

These are just some of the questions companies are grabbling with now. The answers are not necessarily easy, so it is important to think through the issues and come up with a plan.

If you have any questions, please contact our office.

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by IAB Admin

Section 122 Tariffs Struck Down by the CIT

CIT Rules Section 122 Tariffs Unlawful

The U.S. Court of International Trade issued a decision invalidating the 10% additional tariffs imposed under Section 122 of the Trade Act of 1974.

The following is a summary from Sidley Austin LLP regarding this ruling.

Earlier today, the U.S. Court of International Trade issued its decision in the cases challenging the legality of the 10% additional tariff President Trump imposed under Section 122 of the Trade Act of 1974 immediately after the Supreme Court struck down the tariffs he had imposed under the International Emergency Economic Powers Act on February 20, 2026. Specifically, the CIT entered a judgment that:

  1. declared that the proclamation imposing the Section 122 tariffs “to be invalid as contrary to law”;
  2. permanently enjoined the proclamation from applying to the subset of plaintiffs that had established standing (certain states that sued did not establish standing);
  3. required the government to implement the permanent injunction within 5 days; and
  4. required the government to refund the Section 122 tariffs paid by the subset of plaintiffs before the injunction goes into effect with interest.

The government is certain to appeal. We believe that the portion of the judgment striking down the tariffs is automatically stayed for 30 days, which will give the government time to seek a stay pending appeal. Since that part of the judgment applies to the tariffs/all importers, a stay pending appeal seems likely (which means importers will continue paying the Section 122 tariffs while the appeal progresses). As for the permanent injunction, it is not automatically stayed, but it only applies to a subset of the plaintiffs.

The court gave the government 5 days to implement the injunction, so we expect it will ask the Court of Appeals for the Federal Circuit to stay the injunction in that time. The question is whether importers should file their own court case and request the same permanent injunction. It is a bit strange that the court appears to be giving importers the incentive to do so, given that the same court is doing everything it can to ensure that importers do not need to file suit in order to get an IEEPA refund. This is not exactly an apples-to-apples comparison, but it is close.

So, in short, importers need to continue paying the Section 122 tariffs upon import for now, and will continue doing so during the appeal unless the Federal Circuit decides not to stay the permanent injunction, in which case, importers will have an incentive to file their own court cases requesting their own injunctions.

If you have any questions, please contact our office.

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by IAB Admin

CBP Releases ACE Reports to Monitor CAPE Refund Claims

U.S. Customs and Border Protection has announced several new ACE reports to monitor CAPE refund claims.

Please see the following notice and contact us at compliance@iab-sd.com if you have any questions.

CSMS # 68536553 - CBP Offers Multiple ACE Reports for Monitoring CAPE Refund Claims

On April 20, 2026, U.S. Customs and Border Protection (CBP) released the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE) Portal to streamline the submission and processing of valid refund requests for duties imposed under the International Emergency Economic Powers Act (IEEPA). After CBP review, the U.S. Department of Treasury (Treasury) will issue refunds via Automated Clearing House (ACH). IEEPA refund ACH transactions will begin as early as May 12, 2026. For more information on submitting CAPE Declarations, review CBP’s IEEPA Duty Refunds webpage.

To help the trade community prepare and monitor CAPE declaration submissions, CBP has provided multiple ACE Reports products. Below is an overview of the available reports:

  • ES-022: CAPE Entry Summary Report
    • This report links CAPE declaration, entry, and refund numbers to help track the refund process and displays refund amounts separated by principal and interest.
  • REV-603: Trade Refund Report
    • This report enables trade users to track CAPE declarations that have one of the following “Refund Secondary Statuses” after the refund is received by Treasury.
      • Sent to Treasury – This status indicates that Treasury has received an approved refund claim.
      • Treasury Issued – This status indicates that a refund has been issued.
      • Funds Diverted – This status indicates that funds have been diverted for an existing bill. Diversion occurs after liquidation of the entry summary, before the refund is issued.
      • Check/ACH Returned – This status occurs when refunds are rejected due to incomplete ACH Refund enrollment.
    • For help running this report, review the ACE Reports Trade Refund Report Quick Reference Card (QRC).
  • REV-613: ACH Rejected Refunds Report
  • REV-615: CAPE Details Refunds Report
    • Building on the REV-603 report, this report provides entry summary-level details associated with CAPE declarations that have been sent to Treasury.

ACE Reports Tips

  • Save Time by Scheduling Reports: To minimize processing time, CBP encourages the trade community to schedule recurring reports and get results delivered to an email inbox. For more information, review the Schedule a Report reference guide.
  • Use ACE Reports to Identify “4811 Notify Parties”: The following data elements can be added to Entry Summary (ES) reports to identify notify party information:
    • CF 4811 Notify Party Name
    • CF 4811 Notify Party Number

Support Resources:

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by IAB Admin

Urgent IEEPA Filing

Please contact our office if you need assistance in filing your CAPE declarations for IEEPA Refunds.

You can reach us at compliance@iab-sd.com for questions.

by IAB Admin

Important Reminder: ACE Portal Access and ACH Refunds

As April 20th is quickly approaching, that is the day we can begin uploading reports into the CAPE system for IEEPA Refunds.

It is essential to have your ACE account set up for ACH refunds. Please refer to the instructions below for guidance.

IAB will be able to help with the process of uploading reports into the CAPE system for you when it is functional.

CSMS # 68179006 - REMINDER: ACE Portal Access and ACH Set-Up Required to Receive CBP Refunds

On February 6, 2026, U.S. Customs and Border Protection (CBP) transitioned to electronic-only refunds, as announced in the Electronic Refunds Interim Final Rule published January 2, 2026, in the Federal Register (91 FR 21). This change was necessitated by 31 U.S.C. § 3332 and President Trump’s March 25, 2025, Executive Order 14247, Modernizing Payments To and From America's Bank Account, 90 FR 14001.

Since February 6, 2026, CBP has had over 12,300 certified refunds rejected because the recipient party did not provide CBP the necessary banking information. If a refund recipient has failed to provide CBP valid U.S. bank account information in the Automated Commercial Environment Secure Data Portal (ACE Portal), CBP is unable to deliver electronic refunds to that recipient.

Importers and other parties who have had entry summaries liquidate since February 6, 2026, and have not yet provided CBP the necessary banking information to effectuate ACH refunds need to follow the instructions in the following ACH refund enrollment resources:

For technical questions, contact the ACE Account Services Desk at ace.support@cbp.dhs.gov. For general inquiries, contact the Office of Trade Relations at traderelations@cbp.dhs.gov.

If you have any questions, please contact our office.

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by IAB Admin

Notice on CAPE for IEEPA Refunds

Important Message about CAPE for IEEPA Refunds

The following notice from CBP regarding processing of entries for IEEPA refunds.

CSMS # 68315804 - Introduction - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment

On April 20, 2026, U.S. Customs and Border Protection (CBP) will launch the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal). CAPE will simplify International Emergency Economic Powers Act (IEEPA) duty refund requests made pursuant to court order and in accordance with appropriate statutory authority by providing an electronic pathway to submit valid IEEPA duty refund claims.

CAPE is designed to consolidate refunds of IEEPA duties including interest rather than processing refunds on an entry-by-entry basis. CBP plans to implement CAPE through a phased development approach, adding more functionality in subsequent phases for more complicated scenarios. CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.

Requesting refunds of IEEPA duties requires only the following summarized actions:

  • Importers of Record (IORs) and authorized Customs brokers have an established ACE Secure Data Portal account (ACE Portal account)
  • Refund recipients use the ACE Portal account to provide CBP with bank account information for refunds
  • IORs and authorized Customs brokers submit CAPE Declarations in the ACE Portal

The CAPE process starts with the filing of the CAPE Declaration in the ACE Portal by the IOR or the authorized broker who filed entries on behalf of the IOR. Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number and recalculate the duties due without IEEPA, updating the entry to a new version. CBP will review the updated version of the entry and liquidate or reliquidate. Refunds will be consolidated by IOR or the party designated via CBP Form 4811 and liquidation date.

IORs and brokers who will be filing CAPE Declarations are encouraged to prepare for CAPE filing by ensuring that they have an ACE Portal account and that their bank account information for refunds has been added to their account. For additional information about ACE Portal access and ACH refunds visit the resources below:

To learn more about CAPE functionality in ACE, please see the CAPE Information Notice. For more information on the CAPE filing process, please see the CAPE Refund Quick Reference Guide.

CBP will continue to issue messaging via the Cargo Systems Messaging Service (CSMS) to ensure the trade community is informed and prepared to utilize this new tool and as new enhancements are deployed.

Technical questions regarding this message should be directed to IEEPARefunds@cbp.dhs.gov. General questions regarding this message should be directed to traderelations@cbp.dhs.gov.

If you have any questions, please contact our office.

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by IAB Admin

Action Required - Important Security Information

Please Complete and Return this CTPAT Questionnaire

As a member of CTPAT, IAB would like to highlight the importance of security procedures in place to ensure that your shipments do not get compromised.

Please see the following guide for more information, complete the attached questionnaire and submit this form back to us:

If you have any questions, please contact our office.

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by IAB Admin