On September 11, the U.S. Department of Commerce published an amendment to the rules on steel and aluminum articles subject to duties and quotas under Section 232 of the Trade Expansion rule.

The changes include a new rebuttal and surebuttal process, the controversial system that allows a company to object to exclusions requested by another company in the sector.   Rebuttal comments are now due as early as September 18. Duties of 25% on steel and 10% on aluminum have been in effect for certain countries since March 23 of this year.

On August 29, President Trump signed a proclamation allowing for the Dept. of Commerce to provide targeted relief from Section 232 import quotas on steel and aluminum. The move was welcomed by some members of Congress and industry as providing improvements to the product exclusion process, including for products that are from countries subject to quotas as well as tariffs.

The exclusion process has been the subject of much commentary, at and beyond hearings, among industry leaders. Industry executives continue to keep a watchful eye on the situation regarding tariffs and other restrictions on aluminum and steel, as well as other products.

Read the amendments published in the Federal Register HERE.

In this rapidly changing environment, we are advising clients to consider the following:

• Know whether your imports are affected and decide what you’re going to do about it.
• If you have a question about whether your products are affected by the tariffs, we may be able to help. We can tell you what impact the tariffs will have on your shipments, and help you file an exemption.
• Don’t panic, but also don’t ignore the possible significant impact to your business.

This continues to be a very fluid situation, and we are here to help you find the proper course of action.

Contact me if we can be of help and check back on our website at www.wbskinner.com for frequent updates.