From: Bill O’Connor | Okie@gsm.international 23 April at
4:17AM
To: Design Orient Agency (j.smith@designorientagency.com) |
j.smith@designorientagency.com
Cc: Billie Heilian | billie@gsm.international
April 22, 2025
GSM International continues to monitor Customs and Border Protection (CBP) FAQs pertaining to
IEEPA tariff actions and has highlighted some recent FAQs of particular interest:
Iron Included in Steel?
An update to Section 232 Tariffs on Steel and Aluminum FAQs clarifies the question that if the
product only has iron content is the imported product subject to section 232 steel derivative duty?
Question: “When an imported product is classified in a HTS subject to Section 232 duties based on
the steel content; and the product has no steel content; and the product has iron content; is the
imported product subject to the Section 232 steel derivative duties?
Answer: No.
Are Auto Parts for Passenger Vehicles and Light Trucks Subject to Reciprocal Duties?
Answer: Per CBP FAQs, auto parts for passenger vehicles and light trucks, as defined by Executive
Order 14257, issued April 2, 2025, and subject to Section 232 duties as of May 3, 2025, are not
subject to the reciprocal duties effective April 5, 2025, pursuant to heading 9903.01.33, HTSUS.
Refer to 90 FR 15041 (April 7, 2025) and CSMS #64680374 and #64701128.
IEEPA Tariffs FAQs for Canada and Mexico
Question: Can I get the 25 percent tariff on USMCA goods refunded for entry dates March 4, 2025 to
March 6, 2025?
Answer: Effective on or after March 7, 2025, goods entered for consumption or withdrawn from
warehouse for consumption from Canada or Mexico that qualify for the USMCA preference are not
subject to the additional tariffs under the IEEPA. The rules that govern whether a product qualifies
for USMCA preference are found in General Note 11 of the Harmonized Tariff Schedule of the United
States (HTSUS). However, goods entered for consumption or withdrawn from warehouse for
consumption from Canada or Mexico between March 4, 2025 and March 6, 2025 are subject to the
additional tariffs under IEEPA. CBP is not able to refund the additional duties under the IEEPA paid
during that timeframe inasmuch as the tariffs were in effect during that time.
Best regards,
Okie O’Connor
U.S. Licensed Customs Broker and International Trade & Logistics Specialist
Mobile # 802-881-4672
“On time, in tact, and in Compliance”
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GENERAL NOTICE OF ADVICE
The advice offered above is strictly an informal opinion and is based solely upon information provided.
Reliance upon this advice does not constitute reasonable care under the Customs Modernization Act. In order
to exercise the highest degree of reasonable care, GSM Inc. recommends that our clients perform a complete
review, which may include an application for binding ruling from the U.S. Customs and Border Protection.
Should you wish assistance with this matter please let us know.
