On June 29, 2026, U.S. Customs and Border Protection (CBP) released CSMS # 69087399, providing guidance for the import adjustment offset program applicable to Section 232 duties on automobile and medium and heavy-duty vehicle (MHDV) parts. We summarize below the latest guidance from CBP and procedural steps for claiming offsets against Section 232 duties.
Eligibility and Tracking Limits: The duty offset is not a blanket exemption; rather, it may only be claimed by importers who have been specifically granted an offset license by the Department of Commerce (DOC), and only up to the amount authorized under that license. Pursuant to the guidance, importers are advised to track their usage using TR-015 report in Automated Commercial Environment (ACE), as exceeding the granted offset amount will render them liable for Section 232 duties and potential penalty actions under 19 U.S.C. § 1592.
ACE Filing Procedures: To successfully claim the offset in ACE, importers must follow the following procedures:
- Chapter 99 HTSUS Codes: File the applicable Chapter 99 HTSUS codes with a zero (0) duty amount. For automobile parts, use tariff classification number 9903.94.05 or 9903.94.07. For MHDV parts, use 9903.74.08 or 9903.74.09.
- Column One Duties: Concurrently, file the standard column one duty amount for the corresponding Chapter 1 – 97 HTSUS when the license number is submitted on the entry summary line.
- Chapter 98 Exemptions: If submitting special classifications under Chapter 98 (9802.00.40, 9802.00.50, 9802.00.60 or 9802.00.80) on the same entry line, file a zero (0) duty amount for those as well.
- License Formatting: The DOC provided 8-character offset license number (AANNNNNN) (two letters followed by six numbers) must be submitted in the Importer Additional Declaration Field (54 record) using Type Code 11 (Offset License) on the entry summary data.
Country Specific Calculation Rules: Special calculation rules apply to automobile parts originating from Japan, the United Kingdom, European Union member countries, South Korea and Taiwan. For imports from these countries, the offset can only apply to the specific portion of the tariff assessed under Section 232, which is calculated as the difference between the total combined tariff and the standard column one rate. In other words, the offset only applies to Section 232 duties and not the underlying Column 1 duty. Additionally, imports from these countries must use the following:
- Chapter 99 HTSUS Codes: File the applicable Chapter 99 HTSUS codes with a zero (0) duty amount. Importers must use a designated set of tariff classifications under 9903.94.43, 9903.94.55, 9903.94.32, 9903.94.33, 9903.94.53, 9903.94.45, 9903.94.63, 9903.94.65, 9903.94.67, or 9903.94.69.
- Column One Duties: File the standard column one duty amount for the corresponding Chapter 1 – 97 HTSUS when the license number is submitted on the entry summary line.
Post Summary Correction: Importers who have already paid Section 232 duties on eligible entries can submit a PSC to amend previous entries and credit those paid duties against their authorized offset license.
Exemptions: Note that filing the Chapter 99 HTSUS with the offset license number automatically exempts the imported parts from other Section 232 metals or wood duties.
The Husch Blackwell International Trade and Supply Chain team will continue to monitor this and provide updates as they become available. If you have any questions or concerns, please contact your Husch Blackwell attorney.