04/04/2025
U.S. Tariffs – Latest Client Updates
Check out this week’s Customs Corner to read about U.S. tariff updates, import duties on imports of certain aluminum derivative products, and more.
Trade and Customs Updates
1) U.S. Tariffs – Latest Client Updates
GEODIS has published a Market Advisory providing information into the Reciprocal Tariffs, Revocation of De Minimis for China, and the additional tariffs on Automobiles and Automobile Parts.
A Market Advisory has been distributed to clients and posted on our website: U.S. Tariffs - Latest Client Updates | GEODIS. Please note that the Official Federal Register on Reciprocal Tariffs has not yet been published, and we are awaiting confirmation of certain details. Additionally, CBP is updating tariff rates in select publications. Until the official CBP guidance is released, the information within the Market Advisory should only be considered a reference for guidance.
During the April 3 bi-weekly ACE trade support call, a CBP official stated they are actively developing a CSMS messaging to provide further technical instructions and guidance on the reciprocal tariffs and revocation of de minimis for China.
GEODIS will provide links to the Federal Register and CSMS once they are published
2) Import Duties on Imports of Certain Aluminum Derivative Products
ACE incorrect requirement to report Section 232 duties on certain HTS has been fixed.
As of March 12, 2025, ACE mistakenly required Section 232 duties under HTS 9903.85.08 for imports classified under HTSUS 8418.99.8010, 8418.99.8015, 8418.99.8020, and 8418.99.8025. This error was corrected in ACE on March 27, 2025, and filers are no longer required to transmit 9903.85.08 with these classifications.
Filers who paid Section 232 duties on affected imports since March 12, 2025, should submit a PSC to correct entry summaries and claim a refund.
For unliquidated entries, a PSC can be filed to request a refund.
For liquidated entries, a protest may be filed within 180 days of liquidation to seek reimbursement.
Reference:
CSMS # 64605146 - Update: Import Duties on Imports of Aluminum Derivative Products
3) Beer and Aluminum Cans are Added to Section 232 Derivative List
Effective April 4, 2025, a 25% tariff will apply to beer and empty aluminum cans, as outlined in BIS’s Federal Register notice.
On April 4, 2025, BIS published the notice in the Federal Register, Implementation of Duties on Aluminum Derivatives Beer and Empty Aluminum Cans Pursuant to Proclamation 10895 Adjusting Imports of Aluminum into the United States, revising Annex 1 to add aluminum derivative products subject to the 25 percent ad valorem tariffs on imports from all countries effective on or after 12:01 a.m. eastern daylight time on April 4, 2025.
ENTRY FILING INSTRUCTIONS
Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 4, 2025, the following Chapter 99 HTSUS classifications apply for goods imported under HTSUS 7612.90.10, 2203.00.0060, and 2203.00.0090:
For HTSUS 7612.90.10:
- 9903.85.07: Derivative aluminum products listed in subdivision (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232).
25 percent ad valorem duty.
For HTSUS 2203.00.0060 and 2203.00.0090:
- 9903.85.08: Derivative aluminum products listed in subdivision (k) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232): the import duty is based upon the value of the aluminum content.
25 percent ad valorem duty
See CSMS #64384496 for instructions on how to report the value of the aluminum content.
For HTSUS 2203.00.0060, 2203.00.0090, and 7612.90.10:
- 9903.85.09: Derivative steel articles listed in subdivision (j) or (k) (new derivative aluminum articles), where the derivative aluminum products were processed in another country from aluminum articles that were smelted and cast in the United States.
0 percent ad valorem duty
Duties for Aluminum from Russia
The 200 percent duties on any derivative aluminum products subject to Section 232 that are products of Russia, or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or where the aluminum articles are cast in Russia, are still in effect. These duties are to be applied on the entire value of the imported good. Importers should continue to report HTSUS heading 9903.85.68 for aluminum derivative products subject to the 200 percent Russia aluminum duties.
SMELT AND CAST REPORTING REQUIREMENTS
See CSMS #64384496 for instructions on how to report the smelt and cast fields.
Instructions To Submit Entries for Products That Do Not Contain Aluminum Content, And Are Not Subject To Section 232 Measures, But Still Require The Aluminum Smelt And Cast Information To Be Reported
Where the product does not contain aluminum content, but has a HTSUS classification that would be subject to Section 232 measures on derivative steel or aluminum articles if it contained aluminum, ACE will still require the aluminum smelt and cast country to be reported.
For such situations for aluminum derivative HTSUS classifications, where the aluminum country of smelt and cast is required, report “Y” for the secondary country of smelt, and report the country reported as the country of origin of the non-aluminum article as the secondary country of smelt code, and as the country of cast.
For all other fields, continue to follow the CATAIR including reporting on one entry summary line for non-Section 232 entries.
DRAWBACK
No drawback shall be available with respect to the duties imposed pursuant to Proclamation 10895.
FOREIGN TRADE ZONE
Any aluminum articles or derivative aluminum articles, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, that is subject to the duty imposed by this proclamation and that is admitted into a U.S. foreign trade zone on or after the Commerce certification date, in accordance with clause 9, may be admitted only under “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTSUS subheading.
Reference:
CSMS # 64639013 - GUIDANCE: Section 232 Additional Aluminum Derivative Products
4) Without Release Order (WRO) on Taepyung Salt Farm’s Sea Salt Products
CBP has issued a WRO against Taepyung Salt Farm due to forced labor violations.
Starting April 2, 2025, U.S. Customs and Border Protection (CBP) will detain sea salt products from Taepyung Salt Farm due to concerns over forced labor. This action falls under 19 U.S.C. § 1307, which bans imports made with forced or indentured labor. Importers can contest the detention by proving admissibility or opting to export the goods.
Reference:
CSMS # 64637741 - Withhold Release Order (WRO) on Taepyung Salt Farm’s Sea Salt Products
5) U.S. Food and Drug (FDA) Supplemental Guide Version 2.5.12 is Now Available
The changes within the FDA Supplemental Guide version 2.5.12 have been deployed and are now available on CBP.gov.
FDA Supplemental Guide - Version 2.5.12 includes additions to mandatory Intended Use Codes (IUC) for the following commodities:
- Cosmetics (Program Code COS)
- Ceramicware and other food contact substances (Program/Processing Code FOO/CCW)
- Pharmaceutical Necessities, Containers, Inactive Pharmaceutical Ingredients and Excipients (Program/Processing Code DRU/ PHN)
- Veterinary medical devices (Program/Processing Code VME/ADE)
In addition, the following changes are included in the SG:
- IUC 110.000 has been added for Human Drugs (Program Code DRU and Processing Code PRE (prescription) and OTC (over the counter)).
- Medical Devices IUC 170.000; Affirmation of Compliance IFE is no longer required.
References:
6) Chile to Provide Electronic Certification to U.S. Department of Agriculture
Beginning April 14, 2025, Chile will begin providing eCerts to USDA and FIS.
The government of Chile will be sending electronic certification (eCert) data to the U.S. Department of Agriculture (USDA), Food Safety and Inspection Service (FSIS) for products under FSIS jurisdiction exported to the United States beginning April 14, 2025. Once implemented, paper inspection certificates issued by the Central Competent Authority (CCA) in Chile will not be required by FSIS.
Reference:
7) Canada’s new Organic Import Requirements
Organic Certificates for organic goods imported into Canada will be required effective May 26, 2025
Anyone importing organic products must have a valid organic certificate, which currently must accompany each shipment and be presented upon request. The certificate must be issued by a certification body that is accredited by the Canadian Food Inspection Agency (CFIA), or by an accredited body recognized under an existing organic equivalency agreement between Canada and a foreign country. More information can be found here.
Beginning May 26, 2025, importers and brokers will be required to provide a digital copy of the organic certificate as part of their Integrated Import Declaration. The Canada Border Services Agency will assign a unique reference number (URN) for each uploaded certificate, which can be used as part of the submission when completing the declaration. This will allow importers to use the same URN for multiple shipments.
Failure to upload a copy of the certificate or URN will result in a reject until the certificate or URN is provided.
A list of subject products can be found on AIRS by using a keyword search – the affected products include plant products, meats, prepared food products, and essential oils.
Canadian Society of Customs Brokers is hosting a May 15 webinar on the upcoming import requirements for organic products.
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