04/18/2025
CBP ACH Debit Considerations Due to Increased Tariffs
Check out this week’s Customs Corner to read about debit considerations due to increased tariffs, Section 232 investigation, and more.
Trade and Customs Updates
1) CBP ACH Debit Considerations Due to Increased Tariffs
NCBFAA published guidance to importers and brokers ensuring banks are prepared to accept larger debit amounts due to increased tariffs.
Due to increased tariffs, importers and brokers should coordinate with their banks to ensure larger debit amounts for duties are accepted. This may require raising the Debit Cap or removing Debit Blockers for Customs and Border Protection (CBP) transactions using the CBP Company ID provided in the original ACH Debit Acceptance letter.
Parties should review ACH reports to confirm debit amounts, ensure adequate account funding, and adjust debit voucher caps. If CBP cannot successfully debit an account, it may issue a debit voucher, potentially remove the participant from the ACH Debit program, and impose penalties.
Additional recommendations for importers using ACH Debit (Pay Types 3/7/8) include:
- Notifying the bank to authorize CBP debits
- Sharing the CBP Customer ID with the bank
- Setting a sufficient dollar authorization limit
- Establishing a daily transaction limit high enough to cover all charges, especially for PMS customers with high billing volume.
2) Section 232 Investigation on Processed Critical Minerals and Derivative Products
President Trump published an Executive Order on April 15, 2025, on actions pertaining to a Section 232 investigation on processed critical minerals and their derivatives.
In the Executive Order it is noted that the United States' national defense and economic stability rely heavily on processed critical minerals and their derivative products, which are essential for key industries and advanced defense technologies. These materials are foundational to sectors like transportation, energy, telecommunications, and military systems.
Given these concerns, the U.S. is launching an investigation under Section 232 to determine whether imports of these materials and products threaten national security.
The Secretary of Commerce is directed to begin an investigation under Section 232 to evaluate whether imports of processed critical minerals and their derivative products threaten U.S. national security.
The investigation will focus on:
- Assessing domestic production capacity, foreign competition, and national defense impacts.
- Identifying U.S. imports of these minerals and derivative products, their sources, and associated risks by country.
- Analyzing harmful economic practices by foreign processors, such as price manipulation and market control.
- Evaluating demand for these materials in the U.S. and globally.
- Review of global supply chain risks and U.S. capabilities to produce and process these materials.
- Report on the value of current imports by country.
A draft interim report must be prepared within 90 days and shared for internal review. Feedback must be returned within 15 days. A final report with recommendations is due to the President within 180 days of starting the investigation.
As a result, the Secretary may recommend tariffs, import restrictions, anti-circumvention safeguards, incentives for domestic production and recycling, or other measures under national emergency powers to address security risks.
Reference:
3) Section 232 Investigation of Imports of Semiconductors
Secretary of Commerce has initiated an investigation under Section 232 on national security imports of semiconductors, semiconductor manufacturing equipment, and their derivative products.
On April 1, 2025, the Secretary of Commerce launched a Section 232 investigation to assess the national security impact of importing semiconductors, semiconductor manufacturing equipment (SME), and related products. The review covers items like substrates, wafers, legacy and advanced chips, microelectronics, SME components, and downstream products containing semiconductors used in the electronics supply chain.
Comments may be submitted at any time but must be received by May 7, 2025.
Reference:
4) Restoring American Seafood Competitiveness
President Trump signed an Executive Order pertaining to the Seafood Import Monitoring Program.
An executive order issued by President Donald Trump, dated April 17, 2025, directs the Commerce Department to reconsider aspects of the Seafood Import Monitoring Program.
The United States aims to strengthen its seafood industry by reducing regulatory burdens, countering unfair foreign trade practices, promoting ethical sourcing, and ensuring supply chain integrity. This builds on Executive Order 13921 (2020), which improved seafood competitiveness and coastal economies.
The Secretary of Commerce will review and reduce overly burdensome regulations, especially for the most overregulated fisheries. Within 60 days, the Secretary of Commerce and the U.S. Trade Representative must, with input from the Interagency Seafood Trade Task Force, develop a comprehensive seafood trade strategy. Building on the 2020 Seafood Trade Strategy, it will aim to expand access to foreign markets, address unfair trade practices like IUU fishing and non-tariff barriers, and support a fair, competitive market for U.S. seafood producers.
Within 180 days, the Secretary of Commerce, in consultation with the Secretary of the Interior, must review all marine national monuments and recommend to the President any that could be opened to commercial fishing—while ensuring such actions align with preserving the monuments’ originally designated historic or scientific features.
Reference:
Restoring American Seafood Competitiveness – The White House
5) APHIS Updates Import Requirements for Fresh Avocado Fruit from Guatemala into the United States
The Animal and Plant Health Inspection Service (APHIS) is updating import requirements for fresh Hass avocado fruit (Persea americana var. Hass) from Guatemala to mitigate the risk posed by the stem weevil, Copturus aguacatae.
Effective immediately, APHIS has updated import requirements for fresh Hass avocados from Guatemala due to the detection of the quarantine pest Copturus aguacatae (stem weevil). To continue exports to the U.S., Guatemala’s NPPO must follow a jointly developed Operational Workplan (OWP) outlining pest management and control measures. The NPPO must maintain pest-free production areas and meet all ACIR database requirements. Detection of the pest during inspections will result in regulatory action. This Federal Order also officially adds Copturus aguacatae to the list of quarantine pests.
Reference:
6) Executive Order on Lowering Drug Prices
President Trump signs Executive Order on Lowering Drug Prices and Streamlining the Import Process
The executive order titled, “Lowering Drug Prices By Once Again Putting Americans First” directs the Department of Health and Human Services, through the FDA, to improve the drug importation program under Section 804 of the Federal Food, Drug, and Cosmetic Act. There are many timelines outlined within the Order, however, most notably, within 90 days, the Secretary, through the FDA Commissioner, must take action to streamline and improve the drug importation program under Section 804 of the Federal Food, Drug, and Cosmetic Act, making it easier for states to gain approval while maintaining safety and quality standards.
Reference:
Lowering Drug Prices by Once Again Putting Americans First – The White House
7) NCSD May Webinar Schedule
CBP’s National Commodity Specialist Division (NCSD) has released their webinar services for May 2025.
The following webinars are a part of CBP’s continuing education program.
NCSD’s May Webinar Schedule:
Wednesday, May 14, 2025: Armed and Ready: The Arms and Ammunition of Chapter 93 – The “Armed and Ready: The Arms and Ammunition of Chapter 93” 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 provide an overview of Chapter 93 including classification, restricted merchandise, and partner government agency issues.
Wednesday, May 21, 2025: Classification of Antiques of Heading 9706 – The “Classification of Antiques of Heading 9706” 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 discuss on the classification of antique pieces of Chapter 97, Heading 9706 of the Harmonized Tariff Schedule.
Thursday, May 22, 2025: Decorative Articles of Ceramics of Heading 6913 – The “Decorative Articles of Ceramics of Heading 6913” 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 be on the classification of decorative articles in heading 6913.
Wednesday, May 28, 2025: Overview of 9404: Pillows, Mattresses, Quilted Bedding, Etc. – The “Overview of 9404: Pillows, Mattresses, Quilted Bedding, Etc.” 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 explore heading 9404, discussing what goes where within the heading and what one might think should be classified in 9404, but isn’t. We will touch upon mattress supports (what they are and why they aren’t “furniture”), mattress classification (spring, foam, and hybrid), uncovered innerspring units, mattress covers, eiderdowns, pouffes, throw pillows vs. plush toys, comforters, quilts, what “Pillowtex” means to classification and, in the interest of “Balancing Fair Trade” and acknowledging that what you don’t know can hurt you, we’ll look at antidumping and countervailing duties on mattresses.
8) Special Agricultural Safeguard Measures for Sugar-Containing Products
The yearly special safeguard trigger for sugar-containing products has reached its limit.
The Administrator of the Foreign Agricultural Service has determined that the yearly special safeguard trigger level has been met and a special safeguard duty on articles containing over 65 percent by dry weight of sugars described in additional U.S. note 2 to chapter 17 will be imposed effective from the date of FRN 2025-06478 (not yet published) through September 30, 2025.
References:
9) US Customs and Border Protection Base Metals Center of Excellence Provides Clarity of FAQ
US Customs and Border Protection posted guidance within their Section 232 FAQ regarding derivative items related to iron content and the reporting requirement. GEODIS reached out to the Base Metals Center of Excellence for clarification on their response and how it applies.
US Customs and Border Protection posted guidance within their Section 232 FAQ regarding derivative items related to iron content and the reporting requirement. GEODIS reached out to the Base Metals Center of Excellence for clarification on their response and how it applies.
Question asked: Are there specific tariff numbers that we would only consider the steel content and not the iron content? Can you please provide a list of those tariffs where only the iron should be considered in the derivative breakdown and also those where only the steel should be considered, to ensure the trade’s interpretation is the same as CBP.
CBP response: HQ recently posted an FAQ that pertains to Section 232 new derivative articles only. If the content is iron there is no steel present, Section 232 duty is not owed, Section 232 Tariffs on Steel and Aluminum Frequently Asked Questions | U.S. Customs and Border Protection:
These are the core and previously existing derivative Section 232 tariff numbers that do not benefit from the iron exception. If the article is classified under these tariff numbers, the Section 232 duty is applicable—
Steel Products
- 7206.10 through 7216.50
- 7216.99 through 7301.10, 7302.10
- 7302.40 through 7302.90
- 7304.10 through 7306.90
- and any subsequent revisions to these HTS classifications.
Steel Derivatives
- nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in powder-actuated hand tools, threaded (described in subheading 7317.00.30); and
nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505, 7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65;
- bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30); and
- body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).
The “doesn’t include iron” scenario is only for Section the 232 “new derivative numbers”, not the original Section 232 tariff numbers (subdivision j), and not the already existing derivative tariff numbers (subdivision l).
Look for “new” (wherever you see subdivisions m- new steel derivative articles classified in Chapter 73, and n- not classified in Chapter 73):
9903.81.90: Derivative iron or steel products listed in subdivision (m) (new steel derivative articles classified in Chapter 73 subject to Section 232)
9903.81.91: Derivative iron or steel products listed in subdivision (n) (new steel derivative articles not classified in Chapter 73 subject to Section 232)
9903.81.92: Derivative iron or steel products listed in subdivision (m) or subdivision (n) (new steel derivative articles processed in another country from steel melted and poured in the United States)
9903.81.93: Derivative products of iron or steel, as specified in subdivisions (l) and (m) (existing derivative steel products, and new derivative steel products in Chapter 73) admitted to a U.S. foreign trade zone under “privileged foreign status before March 12, 2025, and entered for consumption on or after March 12, 2025
Reference:
https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel-faqs
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