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Section 232 Tariffs Must Be 'Owed and Payable' for Reciprocal Tariff Exemption, CBP Says

An exemption from reciprocal tariffs for goods subject to Section 232 tariffs only applies if duties are “owed and payable,” CBP said in an update May 8 to its Section 232 tariff FAQ.

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That means new aluminum and steel derivatives that are listed as subject to Section 232 tariffs but that don’t actually pay them because they have no actual aluminum or steel content don’t qualify for the reciprocal tariff exemption under subheading 9903.01.33, CBP said.

However, that also means that, for aluminum and steel derivatives that are filed on two entry lines for aluminum or steel content and non-aluminum or non-steel content are wholly exempt, CBP said. “The 9903.01.33 exemption can be claimed on both lines, representing the entire article.”