Weekly Trade Policy Update
Conferences
We're headed to ICPA!
Let Us Know If You'll Be There
Sep 13-15
Booth 23
Grapevine, TX
Speaker. Shannon Bryant, "Duty Optimization: A Deep Dive into Unlocking Trade Value." Tuesday, Sep 15, 10:00 AM CT, Heritage 1.
Dinners
Caspian Trade Leadership Dinner Series
- Sep 14: Grapevine
- Oct 20: Chicago
- Oct 21: Milwaukee
The Bottom Line
The new Section 232 duties on drones and drone components are now in effect. We covered the proclamation on August 18, and the duties kicked in September 3 for goods classified in Chapters 85 and 88. CBP has since issued filing guidance in CSMS 69738151. Rates range from 10% to 100%, depending on the drone and its country of origin.
CBP is also looking for more visibility into import supply chains. The agency is asking for comments on new disclosures around the parties involved in an import, supply chain tracing, and foreign export records. The goal is to help identify transshipment used to avoid duties.
Section 232
We covered the drone proclamation on August 18. The new Section 232 duties on unmanned aircraft systems and their components took effect September 3 under Proclamation 11055. CBP has also issued filing instructions in CSMS 69738151, including the Chapter 99 headings importers now need to report.
The rate depends on the drone and its country of origin. Drones with thermal imaging are subject to a 100% additional duty, as are parts for systems weighing more than 25 kg. Drones without thermal imaging carry a 25% additional duty.
Some trading partners are set to get lower rates: 10% for products of the United Kingdom and 15% for imports from the European Union, Japan, South Korea, Switzerland, and Taiwan. CBP says not to report duties under those headings until it issues further guidance.
The duties are already in effect, and the filing requirements have changed. Importers should review entries in Chapters 85 and 88 and make sure the right Chapter 99 heading is being reported based on the product and country of origin.
Sources: CBP bulletin, Federal Register
Rulemaking
CBP is looking at new rules that would require importers to provide more information about their supply chains. The agency is seeking public comment now, before deciding whether to move forward with binding requirements.
The proposals focus on three areas: more detail on the parties involved in an import, technology to trace where goods come from, and foreign export documents filed with a seller's local customs authority before goods are shipped. CBP says the goal is to identify illegal transshipment used to evade duties.
Nothing is required yet. If finalized, the foreign export document requirement could be the biggest change for importers. Comments are due December 1.
Source: Federal Register
Copper reporting. Starting September 14, ACE will reject entry summaries for certain copper articles that are missing the country of smelt and country of cast. The requirement applies to HTS 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10.
A missing country will now trigger a fatal error instead of a warning, so importers will need to have this information in place before filing.
Source: CBP bulletin
Silicon metal duties stay. The International Trade Commission completed its five-year sunset reviews and found that removing the antidumping and countervailing duty orders on silicon metal from Bosnia and Herzegovina, Iceland, Kazakhstan, and Malaysia would likely lead to renewed injury to U.S. producers.
The orders will remain in place.
Source: Federal Register
Screen your drone and component entries
Pull entries in Chapters 85 and 88 for drones and their components. Make sure you're using the correct Chapter 99 heading, from 9903.08.20 through 9903.08.26. The rate varies by product and country of origin, so check both.
Confirm copper smelt and cast before September 14
If you import copper under any of the four affected HTS headings, make sure the country of smelt and country of cast are reported on every entry line. Starting September 14, ACE will reject entries missing either one.
Reach Out to Caspian to Understand Your Impact
More than one HTS code for one product. You can now add more than one classification to a product. If a component is classified differently depending on the variant or destination, you can keep it all on the same product record.
Import Integration Point tariff reports. Upload your Integration Point report and Caspian pulls the tariff data into your entries. If you get a corrected report, upload it again and Caspian updates the entries.
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