06/06/2025
Section 301 Exclusions Extensions
Check out this week's Customs Corner to read more on Section 301 exclusions extensions, updated guidance on in-transit exception for IEEPA tariffs, and more.
Trade and Customs Updates
1) Section 301 Exclusions Extensions
USTR has extended 178 exclusions from those extended in May 2024 and 14 exclusions from those granted in September 2024.
The Office of the U.S. Trade Representative (USTR) has extended 178 tariff exclusions—164 from May 2024 and 14 related to solar equipment from September 2024—through August 31, 2025. These extensions apply to exclusions listed under HTSUS headings 9903.88.69 and 9903.88.70. The update follows public comments solicited in December 2023 and during a 4-year review. The relevant HTSUS text has been revised to reflect the new end date.
- 9903.88.69 and Notes 20(vvv)(i–iv): Exclusions extended from June 1, 2025, through August 31, 2025. The HTSUS language is updated to reflect this new end date. The list of HTS included under this exclusion can be found here.
- 9903.88.70 and Note 20(www): Exclusions also extended for the same period (June 1, 2025, through August 31, 2025), with corresponding HTSUS text updated. The list of HTS included under this exclusion can be found here.
Reference:
2) Updated Guidance on In-Transit exception for IEEPA Tariffs
U.S. Customs and Border Protection (CBP) has updated its guidance on the in-transit exception for IEEPA Reciprocal Tariffs under HTSUS heading 9903.01.28.
Originally, CBP set vessel loading dates of April 5, 9, or 10, 2025, as the cutoff for in-transit exceptions, requiring entry before May 28, 2025.
Updated guidance now allows for in-transit exceptions only if entry is made before June 16, 2025, acknowledging it may still be realistic for such goods to be in transit.
Therefore, heading 9903.01.28 may only be used for goods:
- Loaded and in-transit before 12:01 a.m. EDT on April 5, 2025, and
- Entered for consumption between April 5, 2025, and before June 16, 2025.
This change is intended to prevent misuse of the in-transit exception beyond a reasonable transit period.
References:
3) U.S. Doubles Steel and Aluminum Tariffs to 50%, Revises UK and CBP Rules
Steel and aluminum products and their derivates tariff increased from 25% to 50%.
Tariffs on steel and aluminum products and their derivates have increased from 25% to 50% effective 12:01 a.m. on June 4.
UK-origin steel and aluminum will continue to face 25% tariffs until July 9. After that date—or later—the Commerce Secretary may impose import quotas or raise the UK tariff rate to 50% if the UK is found to be out of compliance with the U.S.-UK Economic Prosperity Deal.
List of steel HTS subject to Section 232 can be found here.
List of aluminum HTS subject to Section 232 can be found here.
The proclamation also reverses a prior CBP rule on tariff stacking. Now, importers must pay the full 50% tariff on steel and aluminum, rather than the 25% rate previously applied under the fentanyl-related emergency tariffs on Canada and Mexico. Additionally, an exemption from reciprocal tariffs has been eliminated for goods subject to Section 232 tariffs—but only the non-metal portions of those goods will face reciprocal duties.
Goods that entered a U.S. foreign trade zone (FTZ) under “privileged foreign status” before June 4 will be taxed at the rate in effect when they leave the FTZ.
Goods entering an FTZ on or after June 4 must also use “privileged foreign status” and will face the 50% rate when released.
Reference:
Adjusting Imports of Aluminum and Steel into the United States – The White House
CSMS # 65236374 - UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
4) Reminder: USMCA Vehicle Certification Submission Requirements
CBP has posted a reminder to the trade community that USMCA vehicle certification requirements are effective May 19, 2025.
Effective May 19, 2025, U.S. Customs and Border Protection (CBP) will begin enforcing new USMCA vehicle certification requirements for passenger vehicles, light trucks, and heavy trucks, as outlined in the Interim Final Rule (IFR) published on January 17, 2025.
Key points:
- Vehicle producers must submit certifications for Labor Value Content (LVC), steel and aluminum purchasing, and Alternative Staging Regime (ASR) (if applicable) at least 90 days before the certification period begins.
- Submissions must include all required data and be sent via an authorized electronic system in accordance with 19 CFR 182 regulations and DOL rules (29 CFR Part 810).
- CBP will assign a unique identifier for each approved certification (LVC, steel, aluminum, ASR).
- Importers claiming USMCA preferential treatment must include these unique identifiers in the entry summary or provide them within one year post-importation.
- These requirements only apply to certifications submitted on or after May 19, 2025. Earlier submissions are exempt.
Reference:
5) Increase in the number of HTS lines per Entry Effective June 14, 2025
The amount of HTS available on each line will increase from 8 to 32 effective June 14, 2025.
According to CSMS # 65265235, effective June 14, 2025, U.S. Customs and Border Protection (CBP) will implement a system enhancement in the Automated Commercial Environment (ACE), increasing the number of Harmonized Tariff Schedule of the United States (HTSUS) numbers that may be reported on a single entry summary line.
This update will expand the current limit from 8 to 32 HTSUS numbers per entry summary line, providing greater flexibility and efficiency for trade users. The line increase includes Reconciliation and Drawback entry summaries as well.
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