9903.82.01 Created

The US Department of Commerce posted a notice in the Federal Register on April 29, 2026 making a technical correction to Proclamation 11021 of April 2, 2026, Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States.

When Proclamation 112021 was released earlier in April, they established 16 new Chapter 99 HTS codes. However, an HTS code to account for items that flag for the steel/aluminum/copper duties (Chapter 99 Note 16(c)) but do not contain any of those three metals was not included. This amendment adds the HTS code of 9903.82.01 to the list to accommodate for this scenario and was added to the HTS in the Revision 7 update this week.

During the past few weeks without this HTS code, importers have been using 9903.82.03 to indicate no metal, however this code is the Section 232 exception code for imported articles containing less than 15% of the designated metal. The new code of 9903.82.01 is retroactive back to April 6, 2026. Importers who filed 9903.82.03 to account for articles with NO applicable metal should amend their entries now to 9903.82.01 instead.

Section 301 Investigation – Forced Labor

On April 28 and 29, 2026, the United States Trade Representative held scheduled public hearings regarding one of the newest Section 301 investigations that was launched earlier in March.

In attendance was delegates from Mexico, Guatemala, Ecuador, Peru, Indonesia, Vietnam and Egypt. Each had a chance to speak and answer questions from the Section 301 review committee. Many expressed their advancements in practices and laws to further ban, track and detect imports of goods into their countries produced with forced labor.

Many delegates expressed their concerns with the US targeting their economies with higher duty rates over the forced labor issue. Countries like Guatemala had recently signed an trade deal agreement with the US that included wording “Guatemala shall adopt and effectively implement a prohibition on the importation of goods mined, produced, or manufactured wholly or in part by forced or compulsory labor. Guatemala shall recognize U.S. government determinations on entities under Section 307 of the Tariff Act of 1930 and shall presumptively prohibit importation of goods from those entities.”

Mexico also explained to the Committee that forced labor laws and practices were required by the USMCA deal signed in 2020 with the US and Canada.

Vietnam stated they have been working to detect and intercept goods made from forced labor due to the Uyghur Forced Labor Prevention Act signed into law in the US in late 2021.

The transcripts of the hearings will soon be available on the USTR’s website.

Section 232 Steel/Aluminum Preferential Treatment for MX and CA Producers

In Proclamation 10984 (Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses Into the United States) issued on October 17, 2025, the President gave the Secretary of Commerce the authority to reduce duty rates by up to ½ on steel and aluminum articles and derivates and no lower than 25%.

On April 22, 2026, the Commerce Secretary issued a notice in the Federal Register on “Procedures for Submissions by Certain Steel and Aluminum Producers Committing to New U.S. Steel or Aluminum Production to Obtain Tariff Adjustments Under Proclamation 10984”

Under this notice, Commerce issued specific requirements for producers of primary steel and aluminum in Canada and Mexico. If the requirements are met, US importers importing steel and aluminum from approved Canadian and Mexican producers can take advantage of a reduced Section 232 duty rate if that steel or aluminum is used for the manufacturing of vehicles and parts in the United States.

Canadian and Mexican producers can start submitting documents to the Department of Commerce starting on April 23, 2026. Documents must be provided for each project outlining their proposed investment plan, location, production details, capacity and milestone commitments. Once approved, companies must provide, on a quarterly basis, a letter from a senior officer summarizing the total shipments, volume and value of imports, and an Excel spreadsheet with detailed information on shipments for both steel and aluminum. If Commerce decides a qualified company has failed to meet its commitments, imports will be liquidated or reliquidated at the higher listed Section 232 duty rate.