In a move to regulate steel imports more stringently, the U.S. government has introduced new requirements that will affect importers of steel and derivative steel products. As of November 21, 2024, importers must comply with specific reporting mandates regarding the origins of their steel products, especially imports of steel and steel derivative products originating in Mexico.
Key Changes in Steel Import Tariffs
Proclamation 10783, effective July 10, 2024, imposes an additional 25% tariff on certain steel products imported from Mexico. As part of the institution of this new tariff, importers must report the the “melt and pour” origin. Importers will now be required to trace, identify and provide the country of melt and pour for imported steel products from all countries, and for derivative steel products imported from Mexico.
The “country of melt and pour” refers to where the raw steel was first produced in a liquid state and then cast into its initial solid form. This initial solid may be in the form of an unfinished item or a finalized product. This information is typically documented on mill test certificates throughout the production process and maintained in most business’ documents maintained in the normal course of business. Importers will be required to provide this information using the International Organization for Standardization (ISO) country code for certain steel imports from all countries. For derivative steel products from Mexico, an “OTH” (Other) code can be used if the ISO code is unavailable. Importers dealing with derivative steel products from other countries may include an ISO code but it is not required.
To ensure compliance, importers must submit a steel mill certificate via the Document Image System (DIS) in the Automated Commercial Environment (ACE) for certain iron or steel imports. The ACE system will be updated to accommodate these new reporting requirements by November 21, 2024.
Products Affected by the New Regulations
The regulations cover a wide range of steel products, as defined in the Harmonized Tariff Schedule of the United States (HTSUS). This includes steel articles classified under specific HTSUS codes and derivative products such as nails, tacks, staples, bumper stampings, and body stampings for agricultural tractors.
Husch Blackwell’s International Trade and Supply Chain team has provided updates on this development previously:
Understanding these changes is vital for businesses involved in importing steel to ensure compliance and avoid potential penalties. The Husch Blackwell trade team is monitoring these developments closely and will provide updates following new information.