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Understanding the new steel import regulations: what you need to know | Husch Blackwell LLP
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Understanding the new steel import regulations: what you need to know | Husch Blackwell LLP

In an effort to more strictly regulate steel imports, the U.S. government has introduced new requirements that will affect importers of steel and steel-derived products. Since November 21, 2024, importers must comply with specific reporting obligations regarding the origin of their steel products, in particular imports of steel and steel-derived products originating in Mexico.

Main changes in steel import tariffs

Proclamation 10783, which took effect July 10, 2024, imposes an additional 25% tariff on certain steel products imported from Mexico. As part of the introduction of this new tariff, importers must declare the “melt and pour” origin. Importers will now be required to trace, identify and provide the country of smelting and casting for steel products imported from all countries, as well as for derived steel products imported from Mexico.

“Smelting and casting country” refers to where raw steel was first produced in a liquid state and then cast in its initial solid form. This initial solid may be in the form of an unfinished item or a finalized product. This information is typically documented on factory test certificates throughout the production process and retained in most business documents maintained in the normal course of business. Importers will be required to provide this information using the International Organization for Standardization (ISO) country code for certain steel imports from all countries. For steel products derived from Mexico, an “OTH” (Other) code may be used if the ISO code is not available. Importers of steel products derived from other countries may include an ISO code, but this is not required.

To ensure compliance, importers must submit a steel mill certificate through the Document Image System (DIS) in the Automated Commercial Environment (ACE) for certain iron or steel imports. The ACE system will be updated to meet these new reporting requirements by November 21, 2024.

Products affected by the new regulations

The regulations cover a wide range of steel products, as defined in the Harmonized Tariff Schedule of the United States (HTSUS). This includes steel items classified under specific HTSUS codes and derived products such as nails, tacks, staples, bumper stampings and agricultural tractor body stampings.

Husch Blackwell’s International Trade and Supply Chain team has already provided updates on this development:

Understanding these changes is essential for companies involved in steel imports to ensure compliance and avoid possible sanctions. The Husch Blackwell sales team is closely monitoring these developments and will provide updates following new information.

(See source.)