CBP posted the following documents for the June 18 Commercial Customs Operations Advisory Committee (COAC) meeting:
Importer Monarch Metals told the Court of International Trade that its stainless steel wire imports are products of Japan and not China, meaning its goods were improperly subjected to Section 301 and Section 232 tariffs. In a complaint filed June 13, Monarch Metals said that under CBP's prior application of the substantial transformation test to steel wire, no substantial transformation occurs by drawing steel rod into steel wire (Monarch Metals v. United States, CIT # 24-00266).
A report on forced labor in critical mineral supply chains identified "major entities" operating in the Xinjiang province of China and documented evidence of their involvement in labor transfer programs of Uyghurs from the region. The report also highlighted the risk that products made by those entities have entered the global market over the previous two years.
CBP created Harmonized System Update 2522 on June 6, containing 52 Automated Broker Interface records and 20 Harmonized Tariff Schedule records. HSU 2522 includes the correction to the query in HSU 2521 (see 2506040065) for the Section 232 aluminum and steel tariff adjustments that went into effect June 4 (see 2506090008).
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As importers respond to swift changes in the deployment of Section 232 tariffs on steel and aluminum (see 2506030071), they should continue to follow due diligence protocols for entry filing -- and that means even when CBP's guidance on additional subheadings for Section 232 steel and aluminum duties doesn't fully align with what's in official documents, such as the Federal Register, multiple customs attorneys told International Trade Today.
CBP created Harmonized System Update 2521 on June 4, containing 73 Automated Broker Interface records and 35 Harmonized Tariff Schedule records. HSU 2521 includes Section 232 Aluminum and Steel tariff adjustments effective June 4.
Widespread problems with transmitting foreign-trade zone entries are one of several technical problems that plague customs brokers and compliance managers as the effects of the Trump administration's rapid policy changes make themselves felt. Compounding the difficulties is the administration's decision to pull back from engagement with the trade industry through its Trade Support Network and the cancellation of bi-weekly ACE calls.
The U.S. District Court for the District of Columbia on June 3 stayed its decision finding that the International Emergency Economic Powers Act doesn't provide for tariffs, pending the government's appeal of the ruling to the U.S. Court of Appeals for the D.C. Circuit. Judge Rudolph Contreras said a stay is "appropriate to protect the President’s ability to identify and respond to threats to the U.S. economy and national security" (Learning Resources v. Trump, D.D.C. # 25-01248).
CBP created Harmonized System Update 2520 on May 31, containing 11 Automated Broker Interface records and three Harmonized Tariff Schedule records. HSU 2520 includes the extension of Section 301 Exclusions 9903.88.69 and 9903.88.70 to Aug. 31 and a partner government agency update.