U.S. Customs and Border Protection has provided the following information on submitting imports of products excluded from the Section 232 additional tariffs on steel (25 percent) and aluminum (10 percent) products.

CBP Guidance on Submitting Imports of Goods Excluded from Steel/Aluminum Tariffs

Importer of Record Information

Once the Department of Commerce approves a product exclusion, the name, address, and importer of record number for the importer of record listed in that exclusion, as well as the associated product exclusion number, should be submitted to CBP. This information is needed to activate the exclusion number in the Automated Commercial Environment so entries can be filed with this number and, for quota exclusions, so goods subject to the quota exemption can be released. CBP activates exclusion numbers in ACE on a weekly basis, in most circumstances by close of business Thursday for any numbers with corresponding importer information submitted by close of business Monday.

Filing Exclusion Numbers

Importers and filers importing products granted an exclusion should submit the product exclusion number in the Importer Additional Declaration Field (54 record) of the entry summary data using the format STLXXXXXX for steel mill articles and ALUXXXXXX for aluminum articles, where XXXXXX represents the last six digits of the regulations.gov docket number. Filers should not submit the corresponding HTSUS Chapter 99 number for the Section 232 duties when the product exclusion number is submitted.

Only products from importer(s) designated in the product exclusion approved by the DOC are eligible for exclusion from the Section 232 duties.

Steel importers must submit mill certificates with their import data as required by 19 CFR 141.89.


Section 232 tariff exclusions are retroactive to the date the request was received by the DOC. To request an administrative refund for previous imports of products subject to an approved exclusion, importers may file a post-summary correction and provide the product exclusion number in the Importer Additional Declaration Field. If the entry has already liquidated, the liquidation may be protested.

Once products are granted a tariff exclusion, Generalized System of Preferences or African Growth and Opportunity Act duty preferences may be claimed on eligible goods. If such preferences were not received on previous imports, and those imports are now covered by a retroactive duty exclusion, a PSC may be used to request a refund of the duties subject to GSP or AGOA preferences.

© [2018], Sandler, Travis & Rosenberg, P.A. Originally published in the [11/12/2018] issue of the Sandler, Travis & Rosenberg Trade Report. Reprinted by permission.