Article by: Rick Walker, Vice President, TradeInsights, LCB/CCS

U.S. Customs and Border Protection has issued CSMS Message #62582900 which seeks to clarify and provide additional information on the melt and pour requirements for additional duties on certain steel imports. Previously, on July 10, 2024, Presidential Proclamation 10783 imposed an additional 25% tariff on certain imported steel articles and derivative steel articles that are products of Mexico. Proclamation 10783 also provided for the following melt and pour requirements on imported steel and derivative steel articles. For purposes of implementing the melt and pour requirements in this and other proclamations, importers of steel and steel derivative articles shall provide to U.S. Customs and Border Protection (CBP) the information necessary to identify the countries where the steel used in the manufacturing of steel article imports, covered by clause 1 of Proclamation 9705, and derivative steel articles, specified in Annex II of Proclamation 9980, are melted and poured.

Reminder: Pursuant to Proclamation 10783, effective November 21, 2024, importers are required to report to CBP the country of melt and pour for certain imported steel articles from all countries; and for imported derivative steel articles that are products of Mexico; regardless of whether Section 232 duty treatment, quota treatment, or exception treatment applies.

COUNTRY OF MELT AND POUR

Country of melt and pour refers to the original location where the raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. The first solid state can take the form of either a semi-finished product (slab, billets, or ingots) or a finished steel mill product. The location of melt and pour is customarily identified on mill test certificates generated at each stage of the production process and maintained in the ordinary course of business.

For imports of certain steel articles from all countries, when reporting the country of melt and pour, the International Organization for Standardization (ISO) country code where steel was originally melted and poured is mandatory.

For imports of derivative steel products, the reporting of the country of melt and pour code or applicability code is only required for products of Mexico. For derivative steel that are products of Mexico only, the applicability code “OTH” (Other) can be used if an ISO code was not provided in the country of melt and pour field.

For derivative steel products that are the product of countries other than Mexico, the ISO code will be accepted but is not required.

A steel mill certificate is required to be submitted via the Document Image System (DIS) in the Automated Commercial Environment (ACE) for iron or steel imports classifiable in Chapter 72 or headings 7301 to 7307 of the Harmonized Tariff Schedule of the United States (HTSUS). See CSMS# 50930928 (February 4, 2022).

The ACE functionality to report the country of melt and pour for certain steel articles and derivative steel will be effective on November 21, 2024.

PRODUCTS COVERED

Per Proclamations 9705 and 9980, and Chapter 99 of the HTSUS, the following steel articles and derivative steel articles are subject to Section 232 measures, and are covered by the melt and pour reporting requirements:

Steel articles are defined at the HTSUS 6-digit level as 7206.10 through 7216.50, 7216.99 through 7301.10, 7302.10, 7302.40 through 7302.90, and 7304.10 through 7306.90, including any subsequent revisions to these HTSUS classifications.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions.