New Tariffs on Steel, Aluminum Take Effect March 23, CBP Will be 'Closely Monitoring' Compliance

CBP will be "closely monitoring importers’ compliance with the Section 232 measures," which take effect on March 23, a CBP spokesman said. "CBP will enforce the remedies imposed by the President under Section 232 on imports of steel and aluminum from covered countries into the United States," he said. "Companies will be responsible for paying the tariff while their exclusion is under consideration. Imports subject to these measures will be processed through CBP’s Automated Commercial Environment (ACE) entry processing system, which CBP uses to determine admissibility and duty requirements for imported goods."

CBP has agreed to consider allowing entries of targeted products submitted before the tariffs take effect but then put on a hold by CBP to have entered before the effective date of the Section 232 tariffs, even where the filer did not request that the date of arrival be the date of entry, said the National Customs Brokers & Forwarders Association of America in an emailed update. Brokers should submit a list of such entries to THOMAS.F.OVERACKER@cbp.dhs.gov, the trade group said. "CBP Headquarters will review the entries and determine whether the date of arrival may be deemed the date of entry even though the entry will be released after the effective date of the 232 order."

CBP is still conducting "research" on what it will consider the date of entry for shipments moving in-bond under an immediate transportation entry, the NCBFAA said. "Whereas we had previously believed that the date of entry was the date that the IT was initiated, CBP has suggested that the date of entry may be the date that the entry summary is filed. While CBP has agreed to research the issue further, in light of the impending deadline, members should consider filing summaries on these transactions immediately," it said.