06/13/2025
Commerce Expands 50% Section 232 Tariffs to Steel-Based Household Appliances Starting June 23
Check out this week's Customs Corner to read about Section 232 tariffs, IEEPA tariffs, proposed modifications to Section 301 trade actions targeting China’s maritime and shipbuilding sectors, and more.
Trade and Customs Updates
1) Commerce Expands 50% Section 232 Tariffs to Steel-Based Household Appliances Starting June 23
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced in the Federal Register that new steel derivative products will be subject to the 50% tariffs under Section 232. The expanded tariff coverage takes effect at 12:01 a.m. ET on June 23, 2025.
The notice updates Annex 1 to include eight additional product categories made with steel, including:
(1) combined refrigerator-freezers under HTSUS subheading 8418.10.00;
(2) small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
(3) washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
(4) dishwashers under HTSUS subheading 8422.11.00;
(5) chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
(6) cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
(7) food waste disposals under HTSUS subheading 8509.80.20; and
(8) welded wire rack under statistical reporting number 9403.99.9020
A 50% tariff will be applied based on the steel content in each product. BIS clarified that while welded wire racks are now listed as steel derivatives, they also remain subject to aluminum-related tariffs under Proclamation 10895 due to their aluminum content.
No other changes were made to the existing list of steel and steel derivative products under Annex 1.
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2) Appeals Court Pauses CIT Ruling on IEEPA Tariffs, Keeps Duties in Place During Legal Fight
On June 10, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) granted the federal government's request to stay the U.S. Court of International Trade’s ruling that challenged the legality of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). As a result, U.S. Customs and Border Protection will continue collecting IEEPA-related tariffs on fentanyl-related products from Canada, Mexico, and China, as well as the global IEEPA Reciprocal tariffs, while the case is under appeal.
The CAFC emphasized that the legal questions raised in these cases are of "exceptional importance" and ordered expedited briefing. In a rare move, the court announced that the entire bench—all active judges—will participate in an en banc hearing, with oral arguments scheduled for July 31, 2025.
Legal observers anticipate the dispute could ultimately reach the U.S. Supreme Court, regardless of how the Federal Circuit rules.
3) USTR Seeks Public Input on Proposed Changes to China Trade Actions Targeting Maritime and Shipbuilding Sectors
The Office of the U.S. Trade Representative (USTR) is requesting written public comments on a proposed modification of certain elements of the Section 301 trade actions targeting China’s dominance in the maritime, logistics, and shipbuilding sectors.
The proposed changes stem from the ongoing Section 301 investigation into China's state-led efforts to control these critical industries, which the USTR says could threaten U.S. national and economic security. In response, USTR has determined that updates to existing trade actions may now be "appropriate" under Section 307 of the Trade Act, which permits modification or termination of actions deemed no longer suitable.
Proposed Changes to Annex III:
- USTR proposes new, targeted tariff coverage for vessels under the U.S. Maritime Security Program, aimed at reducing dependence on Chinese-built ships.
- The fee calculation basis would be changed from Car Equivalent Units (CEUs) to net tonnage, a shift intended to improve enforceability and minimize evasion.
Proposed Changes to Annex IV:
- The provision allowing suspension of liquefied natural gas (LNG) export licenses (paragraph (j)) would be eliminated, retroactive to April 17, 2025, in response to concerns about its impact on the U.S. LNG sector.
- USTR is also seeking comments on potentially revising data reporting requirements (paragraph (k)) and applying restrictions to vessel owners or operators linked to China.
Stakeholders are encouraged to submit comments addressing the potential economic and operational impacts of these modifications. Public feedback will guide USTR’s final decision on the proposed updates.
Comments can be submitted through the Federal eRulemaking Portal. To be assured of consideration, you must submit written comments on the proposed modifications by July 7, 2025.
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4) CBP to Begin Automated Collection of Sanctions Data for Russian Diamonds and Seafood
U.S. Customs and Border Protection (CBP) will soon begin collecting additional required data elements in the Automated Commercial Environment (ACE) for imports of Russian-origin diamonds and seafood, in support of Executive Order 14114. CBP has also enabled a new functionality for disclaiming certain seafood imports, which is now available for testing in the Certification (CERT) environment.
Trade participants can review the updated Implementation of Additional Required Data Elements for Enforcing Sanctions on Russian Diamonds and Seafood Trade Information Notice for further details.
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5) Food and Drug (FDA) New Human Foods Program (HFP) PICSs for Fruits and Vegetables
The Food and Drug Administration (FDA) has created 2 new Human Foods Program (HFP) Process Indicator Codes (PICs) for fruits and vegetables. They are applicable to Industry Codes 20-22 (Fruit/Fruit Products) and 24-25 (Vegetable/Vegetable Products). The PICS are available for immediate use.
PIC/Description
K/Refrigerated, Fresh Cut
Definition: Product (any fresh fruit or vegetable or combination thereof) held at refrigerated temperature that has been physically altered from its whole state (e.g., by chopping, dicing, peeling, ricing, shredding, slicing, spiralizing, or tearing) and this product may be fresh packaged and refrigerated or on wet ice. Examples chopped romaine lettuce, cubed melon and diced onion. Fresh-cut produce can be a single commodity or two or more…
L/Frozen, Fresh Cut
Product (any fresh fruit or vegetable or combination thereof) that is frozen that has been physically altered from its whole state (e.g., by chopping, dicing, peeling, ricing, shredding, slicing, spiralizing, or tearing). Examples include frozen sliced strawberries, frozen chunked mango, and frozen diced avocado. Fresh-cut produce can be a single commodity or two or more…
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6) GBI Enrollment Create-Update Draft Updated
The GBI Enrollment Create-Update Draft document has been updated and can be found here:
https://www.cbp.gov/document/guidance/global-business-identifier-create-update-v21
Please review the table of changes for details. This update includes:
- GE10 Record
- GE11 Record description
- GE20 Note 2
- GE21 Note 1
These updates were deployed to the Certification environment on January 28, 2025 (CSMS# 63860498) and will be deployed to the Production Environment at a later date. CSMS message will be sent advising the Production deployment date.
Reference:
CSMS # 65293868 - The GBI Enrollment Create-Update Draft document has been updated.
7) EPA Finalizes New Chemical Use Notification Rules Under TSCA
The Environmental Protection Agency (EPA) has finalized a rule establishing significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for certain chemical substances that were previously subject to premanufacture notices (PMNs) and EPA orders. Effective August 12, 2025, the rule requires companies to notify the EPA at least 90 days in advance before manufacturing or processing these substances for any newly designated "significant use."
This mandatory notification will trigger a formal EPA review to assess the proposed use's potential impact. Manufacturing or processing activities cannot begin until EPA completes its evaluation and issues a determination. The rule targets entities involved in chemical manufacturing and petroleum refining (NAICS codes 325 and 324110), including importers who are also subject to pre-existing TSCA certification and export notification requirements.
The rule is scheduled for official promulgation at 1 p.m. EST on June 27, 2025. More information, including affected substances and compliance guidelines, is available through EPA’s TSCA import-export portal and the Federal Register.
Reference:
Federal Register :: Significant New Use Rules on Certain Chemical Substances (23-3.5e)
8) Wood Packing Material Webinar
U.S. Customs and Border Protection’s (CBP) Office of Field Operations along with the U.S. Department of Agriculture is hosting a webinar on Thursday, July 10, 2025, at 1:00 p.m. ET titled Wood Packing Material (WPM). The webinar will provide an overview from CBP and USDA representatives who will inform participants on wood packing material regulations, data sets for public use, and resources for stakeholders along with CBP’s enforcement posture.
To register for this free webinar, click here. All registrants will receive the access link for the webinar the day before the event, but entry into the webinar is on a first-come, first-served basis as seats are limited. Following the live event, this and other previously recorded webinars will be available for replay at Trade Outreach Webinars | U.S. Customs and Border Protection (cbp.gov).
This webinar is part of CBP’s Continuing Education Program. The number of credits and credit code will be provided at the end of the webinar. If you have any questions about this webinar, please contact [email protected].
9) NCSD July Webinar Schedule
To register for these free webinars, click on the registration link for the coordinating webinar below. All registrants will receive the link for the webinar on their confirmation email and the day prior to the scheduled webinar via the OTR Webinars mailbox, but entry into the webinar is on a first-come, first-served basis as space is limited. After the live event, this and other previously recorded webinars will be available for replay at Trade Outreach Webinars | U.S. Customs and Border Protection (cbp.gov).
Tuesday, July 1, 2025: Understanding Festive Article Classification – The “Understanding Festive Article Classification” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar is a guide designed to help explain the often-confusing subheadings of Chapter 95, festive articles. We will go line by line to see where most festive items are classified.
Tuesday, July 8, 2025: Overview of Activated Carbon – The “Overview of Activated Carbon” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar overviews what active carbon is, how it is treated in the Harmonized Classification System, and a brief look at antidumping case number A570-901.
Tuesday, July 15, 2025: Skincare vs. Medicaments – The “Skincare vs. Medicaments” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar will address the proper tariff classification of preparations for the care of the skin of heading 3304 versus medicaments of heading 3004. Educating the trade community about the correct classification of these products will promote balanced and fair trade
Thursday, July 17, 2025: Trends in Classifying Coated Fabrics – The “Trends in Classifying Coated Fabrics” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar will touch on the nuances of classifying coated fabrics as industry and technology evolve and will also cover a handful individual examples/case studies to provide clarity in classifying such goods within the Harmonized Tariff Schedule.
Wednesday, July 23, 2025: An Overview of Novelty Hats and Other Headgear– The “An Overview of Novelty Hats and Other Headgear” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. The webinar will focus on some of the innovative headgear classified in Chapter 65 and will gain valuable insights into the distinct categories of novelty headgear including design characteristics as well as relevant classification aspects.
Tuesday, July 29, 2025: Flying the Friendly Skies in Drone and other Aircraft– The “Flying the Friendly Skies in Drone and other Aircraft” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. The webinar will cover CBP’s definition of parts and proper classification of aircrafts parts. Also, this webinar will discuss the history of drones, the FAA regulations concerning drones, and some issues that have arisen with the popularity of drones.
Thursday, July 31, 2025: Industrial Controls Part 3 – The “Industrial Controls Part 3” is part of the 2025 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This is the third and final component in the Industrial Controls Series of webinars where we will do a short recap of parts one and two and then discuss in detail the tariff classification of programmable controllers, advanced electrical control apparatus, supervisory control, and data acquisition systems.
10) CBP and Port of Portland to Host Revamped Steel Seminar in July
The Base Metals Center of Excellence and Expertise, in partnership with the Port of Portland, will host an updated Steel Identification, Classification, and Trade Law Seminar on July 29–30, 2025. The two-day program, significantly revised from previous sessions held in Portland and other ports, will feature presentations from technical, legal, and commercial steel experts aimed at educating U.S. Customs and Border Protection officers, federal agency staff, and customs brokers on key steel import issues.
This year’s seminar includes new content on Section 232 tariffs, trade fraud, evasion, and circumvention, reflecting the evolving challenges in steel trade. Open to all members of the trade and government community, the event welcomes participants nationwide. Attendance is free for federal employees, but space is limited—early registration is strongly encouraged. More information, including registration details, the preliminary agenda, and a list of speakers, is available at www.steelseminar.us.
EVENT: Managing Tariff Disruptions with GEODIS x CoreTrust Webinar
June 17, 2025 at 1:00 PM CT | Webinar
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