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Marcus Eeman
Hello there. Good morning. Welcome to today's webinar. This is about an urgent briefing on section two thirty two changes. Pretty heavily focused on the steel and aluminum. So if you were here for pharmaceutical, you will get a little shout out, but I just setting up from the beginning here. I am focusing mostly on the steel and aluminum changes. That's where most of the logic was, and it's already happened. So, if you're here for pharmaceuticals, just note you're you're not gonna get quite as much as you wanted. But, my name is Marcus Iman. I'm a customs director here at Flexport, and I wanna go through kind of a smaller but more focused briefing on this February, the logic changes that have happened here. And so before we begin, wanna go over a few housekeeping items. On your screen, you will see a sidebar on the right of the main stage where you can submit questions. At the end of the presentation, we will share a host q and a, and answer a few audience questions, so be sure to get in questions early. In that same sidebar, you see a tab labeled documents. This is where you can, download a copy of today's slides and find other helpful resources like our tariff simulator and our tariff refund calculator. But before we begin, just a quick, legal note. Keep in mind that all information provided during the session is based on the situation at the current time and may not be customized to your specific business requirements. We will always recommend reaching out to a Flexport expert to discuss your particular situation. So, I am Marcus Heman, and I am a customs director here at Flexport, and I'm gonna be your presenter today. For the agenda, we're just gonna talk about a little bit about section two thirty two, kind of how the changes here fit into the overall context, of the two thirty two changes. We're gonna talk about very specifically what are the things that changed and what are the things that didn't change. We're gonna go through, should I expect to be paying more or less, or how do I know? And then we'll leave some time at the end for for q and a, but this is just kind of a mini webinar just to be focused more on on the impact of these changes to talk about it to for your business. So, section two thirty two overview. What is section two thirty two? I think most of us by now probably have some some idea of it, but if you're new to webinars or you just heard about it or your trade compliance manager got really excited, you didn't know why. Section two thirty two, it was part of an act that was, on the books for a while, and it basically allows the Department of Commerce to conduct investigations and to make recommendations on trade restrictions, based on national security grounds. Meaning, we, in the event of a war or some other kind of national crisis, we need to have a certain level of tariff barrier to, foster domestic industry in that space. And with these investigations, there's a prescribed two hundred and seventy day timeline in which these investigations need to be completed. At the end of that investigation, the Department of Commerce makes a recommendation to the president to say, we've looked into it. We don't think we have enough, you know, for example, steel capacity, steel production capacity in The United States. And what we'd like to do is we'd like you to place a certain tariff level on it. We'd like you to place a quota restriction on it. We want you to implement some sort of licensure regime or whatever the whatever the recommendation is. And then the president will will sign an order, and enact tariffs, in this case, pursuant to that investigation. This was used very, very little, up until 2018 when, under Trump won, we started investigations into, steel and aluminum, and then also even at the very end of his are also in there as well for auto parts, although the auto parts would take some years to come to fruition. This was mostly focused to kind of the original kind of steel and aluminum products that were more related to, like, mill products, steel bars, sheets of aluminum, rolls of aluminum, ingots, that sort of thing. Less so of, like, kind of the smaller products, which we are now calling derivatives, right, derived from some of these steel and aluminum industries. And within the two thirty two process, there's also this ability of, like, an inclusions process. So inclusions are basically saying, okay. The Department of Commerce or the BIS will submit comments from industry saying, are there any other things that we should, you know, make sure are subject to two thirty two tariffs on a go forward basis? Because these are also relevant industries that we wanna make sure have good domestic protection in the event of a war or some other national crisis. So we've already seen inclusions add to the steel and aluminum list twice last year. There could be a third one coming, and we're we're not quite sure yet. But we'll actually get to how this latest update actually added 25 new HTS codes to the to the process that weren't previously impacted. So these kind of inclusions are ongoing, but we've only really seen them happening with steel and aluminum. Steel and aluminum are just kind of a two headline investigations that are the biggest, maybe the most expensive, maybe the most well known, but I did get it all on a single slide of all the other investigations for section two thirty two that are ongoing. And some of these you may have also heard of. So the passenger parts, copper, timber, semiconductors, pharmaceuticals, critical minerals is still happening. UAV is still happening. PPE is still happening. A lot of these things are still kind of in process here, and I kinda highlighted it by the two hundred and seventy day timeline. Right? So within the two hundred and seventy days, there should be the investigation closed. Tariffs are recommended. The president should act. So here, you can kinda see how long are these historically taking. Seal and aluminum kinda came together pretty quickly. It's gone through several iterations. More things have added. There used to be an exclusion process. That process is now over. There's more provisions now for US content, which then changed again, which we're gonna talk about, and they've been adding new products. Auto parts kinda sat there for a while. Didn't really have any any action on it until last March. And recently, we just now saw pharmaceuticals see some action as well. Semiconductors could have been a bigger one. If you attended some our previous webinars, you know that the two thirty two rates for timber and lumber were supposed to go up in January from their 1025% levels to, you know, to to 2030% levels. But those those were not passed on. So they did not actually increase them at the end of the year like they they thought they were going to, and they also haven't expanded it. And I'll also clarify that some of the scopes of these investigations, you should know, are quite broad. And so I think one that I expressed being nervous about was the semiconductor one because the way that the investigation was said is that, you know, we have semiconductors. Yes. But semiconductor derivatives could have been a very wide variety of products, maybe anything with a semiconductor in it. So everything from high-tech phones and and computers and smartwatches to, programmable margarita machines or something else. Fortunately, the semiconductor manufacturing semiconductor and manufacturing equipment order was fairly narrow. The investigation was pretty limited, and there's quite a few exclusions such that there's only a handful of chips that are really subject to this 25 mostly focused in the AI space. Many other chips are actually qualified for one of the one of the exclusions here. The other one we've been seeing is auto parts as well. And so with the medium and heavy duty vehicle parts, there's been an additional changes there about how it can apply and can people opt into it or not, which was more valuable under certain, conditions, but is maybe a little bit less so a result of some of these changes. So still plenty more to come here. A few of these investigations have kinda aged out of that two hundred and seventy day investigation timeline. May take a little bit longer. We'll have to see, but, we'll be we'll be watching closely and giving updates as they come in. Okay. So that was section two thirty two. So what changed? What happened on Thursday, and that what went into effect, yesterday on Monday? Well, there's roughly five large things. The first one is that there's no more content breakouts. So if you had partial aluminum content, you were allowed to you know, as of last June, you were allowed to report out the difference between what is the aluminum content and the nonaluminum content. What is the steel content? What is the nonsteel content? And to only pay the 50% rate on that steel or the aluminum content, paying only the IEPA rate or now the section one twenty two rate on the nonmetal content. So that breakout process is over, which is gonna have mixed results. There's no more line splitting for which every customs broker in America is probably happy about, and there's no, metal specific codes anymore. So no having to decide that I use the aluminum code here when I should have used the steel code. Fortunately, it's all just now one code for any of the metals, are now steel, copper, aluminum that are subject to two thirty two. There's only one code that gets applied regardless of what the metal is. Now there's still you need to know what the metal is, and that comes into play a little bit later. But for the for now, there's no specific codes you'd have to keep track of. The high level rates is that for the metal intensive products, which kind of a category I'm making up here, but the kind of these original two thirty two products from 2018 that have kinda gone through some different versions and iterations, These are more metal intensive. These are more of those industrial parts, ingots, bars, rods, coils, those sorts of things. Those are more of the 50% rate. There's also the derivatives, which are products that are made with those things but usually undergo more processing, and that has a 25% rate. And that's both applied to the full value, the full entered value of the product. There is no breakout based on how much metal content is there. Is there 40% aluminum and only paying 50% on that? That process has gone away. So for some, that will be advantageous. For some, this will be a higher cost. But what is, you know, what is a good overall is the silver lining is it is simpler to understand. It is easier for us to understand, not only for importers, but frankly, probably for CBP as well. This has not been something probably easy for them to audit, and so they're probably gonna have a little bit of an easier time following up on this as well. We've also clarified on a go forward basis that the way that they're using content as described for the purposes of an exclusion, is they're talking about weight. Before, it was unclear if they're talking weight or value, which has led to quite a few debates and back and forth for the last year. But they're clarifying now that as they talk about content, they're really looking toward weight. What is the weight of the metal in here relative to the weight of the entire product? That is a that's, I think, a notable change. Another one that I think is important to see is that several previous categories are now excluded. So a lot of things were kind of included in these two thirty two lists over time that kind of led to some wacky results, maybe some unintended results. So pictured on the right, you see aerosol cans. You see metal furniture. Many of these products were subject to two thirty two, duties before, and so you had to kind of find out the metal content of this. And this led to some very difficult situations where it's okay. I I'm an importer of paint, but now I have to know the country of smelt and pour for the paint can. Right? And how much is that paint can valued of the paint itself that it holds? Another one that I remember very vividly is if you import a plastic bucket that has a metal handle, you need to know what is the value of that handle and from what country was the steel that handle melted import. These were not easy questions to necessarily answer. So many of those are now excluded from two thirty two duties, which were not previously or which were previously included and probably led to quite a bit of back and forth. So many things here, sporting goods, canned beer, those sorts of things are now now excluded. There are more exclusions now as well for de minimis content. So you may have been seeing this, and you maybe maybe you did de minimis in the past, but you see this saying, oh, there's a certain amount of content that isn't necessarily need to be reported. I don't have to pay any two thirty two duties on it. Well, that threshold is 15%, and, critically, that threshold only applies to things not classified in chapter 72, 74, 73, or 76. Only things outside of those chapters could get this exclusion, but it does now exist. This was also a great thing for people that I know were importing, you know, like cosmetic dispenser pumps. Right? And they had to try to find out the metal value of the spring inside that pump and how much of a pain that was. That is now, fortunately excluded for them. They're no longer having to, having to report that. There's another exclusion from these two thirty two duties for motorcycle parts, which not only includes, you know, probably Harley Davidson and other kind of US based manufacturers and names that we know, but other kinds of things that are considered motorcycles, Things maybe like electric scooters or electric bicycles. Some of those models could be considered a motorcycle for classification purposes. If they're being used in manufacturing here in The United States, there's an exclusion for that. Now what is the manufacturing versus repair? I would kinda lean a little bit more conservative, but I think it's worth a discussion, about that. So if you're involved in any of those industries and you process, those here, there could be an exclusion for you. There's also a reduction in these two thirty two rates for a few different things. One is for US content. And so previously, if your product had US content in it and was melted and poured, you know, steel, you're allowed to break out based on the value of that content. Well, no longer, is it that quite that easy. It has a very high threshold now of 95% US content. So if 95% of the steel or the aluminum was made in The US, was melted and poured, you know, smelter cast in The United States, now you have to have at least 95% of that value. If so, you pay less on that. You'd go down from, these high these higher rates to, like, a lower 15% rate. The other one that is that exists here is for industrial products. So if you think about section two thirty two, the whole point of this is to try to increase domestic production. Right? We wanna be able to make steel in The United States should a war break out. And so, there are now, more reductions for things, kind of all sorts of things like transformers, things like steel ladles, things sort of like plastic injection molding equipment, things like this. They were previously subject to two thirty two, and they still are, but they're subject to a 15% lower rate now, which I think makes sense. I think that's wise policy. If you wanna encourage domestic production, maybe the machinery that does that production should be cheaper. And so it seems like a smart a smart move there from the administration. And finally, there's also a reduction for metal content at the 95% threshold that is made in The UK. No other country deals were were had here, but The UK did get a breakout where if the steel or aluminum produced was made in The UK, that can be subject to a lower rate of 1510%. Okay. The other thing that I saw here that I'd point out is that the Russian aluminum doubling effect is now mostly resolved. I was unable to confirm one of the aspects of it, but I at least know one of the things were, where they say that previously, if you had, something that was subject to aluminum, February as well as steel February, you ran into this problem where if it was Russian sourced aluminum or is unknown sourced aluminum, you couldn't you didn't know where it was made. You had to declare, this unknown value of 200%. You couldn't then add on the steel to that same line, meaning whatever the steel content was needed to be reported on a separate line, which meant you probably overpaid whatever that steel duty was unless you did some other kind of manual and potentially error prone calculation. This at least solves half of that. And what I'm hoping to confirm is to see how the two the Russian aluminum and the one twenty twos play together before, you know, with Aipa, that couldn't be done. They couldn't be in the same line. But now I'm curious to see if they can be, but I was not able to confirm that before the webinar. So hopefully hopefully soon, we'll we'll have an entry come through with one of our one of our Russian sourcing importers here. That does seem to at least be partially resolved. There's quite a lot of the language in there that says if it's subject to the Russian two you know, aluminum, then it's not subject to one of these other ones. And that kind of exclusionary language is certainly very helpful to clarify at least these kind of like crossover cases between, steel and aluminum. Finally, there were 25 new codes added to these lists here. And these codes kinda cover a few things, some cast iron articles, caps, closures, transformers, railcars from eighty seven sixteen. So these were kinda snuck in there. I don't think I've seen too much kinda talking about it, but there were 25 new HSCOs that were not previously on steel or aluminum or copper two thirty two list that are have now been added. So watching those very closely. Okay. Which I think kinda comes to these sort of question of, you know, okay. All these changes have happened now. How does this what does this mean for my business? It's nice to know that my entry process has gotten simpler, but my brokers took care of that. So I didn't have to think about that too much. But now do I pay more? Do I pay less? And I'm gonna start on the ends of this slide here. If your products are in chapter 72 or 74, you're probably paying the same you were before or maybe paying a little bit more depending on how you defined content. If you were somebody who's a little bit more aggressive in trying to, you know, talk about content being the preproduction cost of the metal, you're probably gonna end up paying more. If you were planning the the postproduction cost of the metal content, you're probably gonna be paying about the same at roughly that 52% level. On the far right of the slide here, I kinda say if you import the canned beer, paint, cosmetics, chemicals, sporting goods, metal furniture, things like that, you're probably now gonna be saving $2.32 You were a subject before. You are not subject to anything any longer, to many of these things. Those are kind of the easy cases. The middle part is a bit of a messy middle, and I tried to go through and try to find some of the rules here that we're gonna talk about. But I gotta say it's not quite so so cut and dry. So if your products were in, heading seventy three zero one to seventy seventy three twenty or if your products were in seventy six zero one to seventy six fourteen, you're probably paying more, and you're probably paying more at the 50% level on the full value. If your products are in chapter 73 or 76, but outside of those ranges in the green box, you'll probably need to look at this number that we're gonna talk about, a 37.5% content level. Based on that number, it kinda tells you if you're gonna be paying more or paying less. So I'm gonna walk through at least a couple of examples of how this sort of works in practice here, but keep this sort of, like, these general guidelines in mind. And know that when we get into this kind of these middle two boxes talking about chapter 73, chapter 76, it gets a little bit funky to kinda, hey. To say, you know, at a high level if you're paying more or paying less. So here's an example of a more metal intensive, something that is part of the 50% list. Say we have $10,000 of steel kegs, classified seventy three ten ten, triple zero five. We'll just say non China to keep things simple, and this is something that only appears on the steel list. So though on the left side, you saw how you were paying these duties. Right? So based on whatever your declared steel content was, if you declared it 0% steel content, let trade advisory know right away. You probably made a mistake on your entry here, but just to kind of illustrate the point. Is that a 25%, 50%, 75%, if you were trying to play some of this content game, say, well, manufacturing, annealing, you know, polishing, you know, brazing, all that doesn't count, and you try to lower your steel content threshold, you're probably gonna be going up. And you can kinda see based on the certain content level. Before, you were paying a little bit of one twenty two duties and you were paying 50% on a content, but now you're paying 50% on the value of the keg itself, on the full value overall. So no matter what that steel content percentage was, it's gonna be 50%. If you were somebody that had the post processing cost of steel, if somebody were like, well, I'm gonna include all the manufacturing, welding, shaping, forming, all of that cost, you're probably not gonna see too much of a difference. If you've already kind of been being a little bit more conservative, paying closer to that 50% on on of steel content here, you're probably not gonna be seeing, too much change. Right? Maybe a slight amount. If you said 90%, 95%, well, now you're gonna be bumped up to the full, 100%, at 50% rate. So the 100% value at 50% rate leads to being $5,000. And because you're no longer allowed to break out, this is probably why people are saying, well, the two thirty two process is gonna cost you more. If you did have something like this, you would not be eligible for the 15% exclusion. You would also be paying at the full 50% on the no breakout allowed. That probably means that either you're paying the same, or you're paying more than than where you were depending on how aggressive you were at trying to back out your content and processing costs. But I wanna look at maybe a bit of a counter case, maybe a little bit more of the the optimistic case as well for a derivative. And the reason why derivatives are kinda messy is here. Now I apologize for the abrasive coloring here, but I wanted to kind of make it clear and kind of show that we looked at seventy three nineteen through 7326. We looked at the end of chapter 76, the aluminum articles, and it's not incredibly clear about which products are gonna be which. Those that are colored red are subject to the 50% rate under the new February tariffs. Those colored yellow are subject to 25% under the new tariffs. And none of the above on the screen can be claimed under the 15% weight exclusion. So most of these are here, but as you can kinda see, there's just some kind of fine lines and some slight changes that happen that make something part of the 50% list or the 25% list under the new two thirty two. And that's kinda why I said these sort of middle boxes were a little bit unclear. These are a little bit hard to talk about. So I'm gonna do my best here to kinda go through it, and I'm gonna talk about one particular example here where maybe you are gonna save a little bit of money. If you had $10,000 of bench vices. Right? These kind of steel things. You secure it to a bench, use it to, like, hold things. There's, like, use, like, a screw handle or a couple of teeth. This is something that is actually probably gonna be cheaper. As you can kinda see from the old chart on the left is that you were paying more on the 50% of the content because this was on the this was on a 50% list based on the content. Steel bench vice is made up with a lot of steel. So it's really difficult to get to back out these charges unless you were pretty aggressively trying to back out the cost of processing. If you had been doing so, you may be seeing roughly kind of the same amount. But I think it's really hard to try to say how little value the steel is coming in through through, like, a steel bench price. So you probably are paying a little bit on that higher range here. But under the new regime, you kinda cap out at 25%. So whether or not your steel content was lower, you you probably would be paying a little bit less. So the rule is there at the bottom left that you sort of break even at the 37 and a half percent mark. So if your derivative product has more than 37 and a half percent steel content, this new logic from February is actually a reduction in cost for you. So if you had some of these products that were kinda outside these rings that were here back in the yellow, if you had a product back in the yellow here, if the content is at least 37 and a half percent or more, this is actually a savings for you. These new changes are probably actually gonna be beneficial because if you were declaring content, you were probably declaring, a lower content here. But now with this higher content, you're probably gonna be saving because you're now capped at 25% instead of paying the 50% rate. I'm also assuming here that there is the ability for this 15% exclusion at 0% content. But, again, I would maybe challenge if you have the right HTS. Make sure you look at that very closely if you're if you're gonna be claiming that, but still worth looking into. Okay. So those are a couple of examples of, like, the bane metal and kind of the derivative content and how that works here. But I just wanna go over maybe a few things that didn't change. And so I think the first one is that there's no indication that this is retroactive. I've seen nothing from the CSMS message, any additional guidance, anything in the language to suggest that this is gonna be retroactively applied. Meaning, all that content work you had been doing, you don't have to do it anymore on a go forward basis. But if you were part of PSCs or protests, if you disagreed with CDP's application of how they were doing the content calculation, those fights may still need to happen by just being done in the PSC or protest or or even the CIT process for challenging two thirty two. This is a change only on a go forward basis. And frankly, there's also no resolution on this content debate. They talked about using weight for the purposes of these new two thirty two codes, but they didn't actually say, well, how do I know? Do I use this raw material processing cost? What do I actually use to declare my value content for steel and aluminum retroactively? No indication. No no guidance there. So we're not quite sure how that is. Any of those continuing conversations you've had are the same ones you've been having for the last several months. I think another one is that out of The UK, no trade deal rates. Right? We didn't see any adjustments for Japan. We didn't see any adjustments for Korea. We didn't see any adjustments for the EU. Right? Outside of The UK, no beneficial rates for some of our other trade partners where a deal was struck. And there's also no change really in the logic. So we still look to see auto parts and MHDBP taking precedence over steel and aluminum. So if subject to auto parts and MHDBP, then it's subject there. You don't apply any two thirty two steel and aluminum or copper that overlap. If not an auto part, then you look into applying the steel and metal content. And the same with the one twenty two applications as well. So no change there. I'm still wanting to see exactly what happens with the Russian aluminum in the one twenty two cases. I wanna see how that's written because under IEPA was not good and under you know, even under one twenty two, still seem to be subject to both, but we have to have to see how that how that ends up. And then kind of kind of an ancillary question just because it's top of mind for everybody right now. How does this change the AIPA refunds process, CAPE process? My answer is that there's really no direct effect from this. Like, there's nothing about these two thirty two changes that directly changes this AIPA refund process, the CAPE process. There's no real thing here. But I would kinda say is what is your stance to the content on previous entries? If you're looking to maybe make changes, I would say for PSCs, if something is before that protest window, my general advice would be to file the PSC. As an importer, you are required to correct errors as you discover them, as you find them. So, you know, not knowing your particular situation, just in general, you should probably look to file PSCs if you're currently correct content either up or down. Make sure you do so while you're still in the PSC window. To do so is a practice of good compliance, a good measure of reasonable care as an importer. Protest, again, this one is a little bit trickier because you may have to put these two thirty two ones, especially if you're challenging content, into a separate bucket. I know there's been some questions back and forth about, well, should I be filing protests at all? Isn't Cape gonna save all this? Cape isn't gonna deal with entries that are under protest in their phase one. What should I be doing here? I would at least say for the protest process, if you have two thirty two changes that you're gonna make via a protest, they should be in a separate bucket from your other just pure IEPA refunds that you're gonna be protesting. Just because, remember, protests can only be about can only group entries together if they're about a single issue. So if you have questions about doing a two thirty two valuation change or content valuation change in addition to an IEPA refund because of a split line, make sure those are kind of bucketed separately. And that's kind of my general advice there for handling protests. Okay. With that, we do have just a couple of minutes here for q and a. So let me go to my question list. I'm actually gonna stop for a quick drink of water. A second. Alright. Where can we find a list of the new, exclusions? That list is, part of the annex. It was annex two in their announcement from the White House. You can see all sorts of it. Like I said, mostly has to do with chemicals, bug sprays, cosmetics, sporting goods, paints, some furniture, exercise machines. Those were the ones that had the the first, the new exclusions here as well. And then it would be under article f, for, the motorcycle the motorcycle exclusions as well. So if a product is less than 15% by weight of aluminum, steel, or copper and the HTS is not in chapter 72, 73, 74, 76, section two thirty two can be disclaimed entirely. Does the total product weight include packing and all the contents of the finished product? Yes. So you need to know the full weight of the final product that you're importing, and you'd need to know the weight of the metal content within this. So does now does that include some of the packing and packaging material? My instinct would probably say no. It probably does not. The reason why is I would worry that customs could see a lot of gaming with all of a sudden, a lot of products are now imported in wood or, lead or other boxes here. I would imagine if you included packaging, importers could try to play some games with the total packaging weight. So I would anticipate it just being based on the on the product weight itself, but it's a fair question. It's I appreciate the creativity. Maybe customs will will override it, but I think, just look for the full product weight only. Let's see. So prior to this change, we were declaring a cost of the aluminum included in the component being imported. Therefore, 50% duties on that amount. Does that mean I will be paying 25% or 50% of the total good value, which has a lot of process costs involved? Yes. Correct. That's exactly what this is gonna be doing. And so if you were kinda backing out that raw metal content before, if you were saying, okay. Well, the, you know, the aluminum only cost $5, and then it was processed further, which added $10, but I'm just gonna say my metal content was only worth 5. You customs is saying you can't do that anymore. I mean, that's kind of been their position for the last few months. They've been issuing CF 29 to that effect. The base metal c has issued guidance kind of pointing the other way, which, again, is not official position, but it's kind of the unofficial guidance from CBP saying that the way that they are treating enforcement is that, it's based on the full, the full processing cost as well. But this kind of goes around that where they're saying it's just based on the entered value of the goods, which would necessarily include any of that processing cost. There's nothing now to back out. Yeah. For the new 15% content weight exemption, if your product contains steel and aluminum and or copper, do the collective weights of those items add up to that 15% threshold to meet the exemption? Yes. If it's on each of those lists. So if it is on a steel list and aluminum or steel and aluminum and copper, you would sum those weights together to get to see if it exceeds that 15% threshold. So things kinda like wiring kits, things like transformers were both on aluminum and copper. Things of that nature. Some of the, some of, like, steel wiring parts as well, I think, also, was on the aluminum list. So those sorts of things, yes, you would add together, but it does have to be on both. So an update the tariff simulator is updated with most of these things here. If you are familiar with our tariff simulator, that's that's been updated with the one with the two thirty two changes. The one thing we're still gonna be doing here very very soon is adding in some sliders to kinda help you identify, okay, which things are subject to both steel and aluminum so then you can copper. So you can input that steel, aluminum, and copper content, and we'll do the math for you to find whatever that if you hit that 15 threshold or not. Let's see here. If the products are derivatives that are now excluded, will we still need to declare country of cast and smelt? Yes. As of today, we are still seeing that they are being requested to report country of cast and smelt. I would also note on that same threshold that we haven't had to report copper, casting and smelting before as well. But now with The US content exclusion for copper, I am anticipating CDP is gonna start to collect this data for copper as well. So if you're importing copper articles, copper derivatives, I would anticipate needing to know the the origin of that copper smelt and pour cast or whatever the metallurgical terminology is for the the melting and production of the copper. So, yes, that is still something that we're gonna that we're gonna see here. Okay. Is there any return of previous two thirty two duties paid? No. Not as a result of this. As as far as I can tell, this is not going to be retroactive. There's no indication that it that it will be retroactive here. Let's see. Is there is CBP likely to go back and scrutinize entries where they disagree with an importer's two thirty two valuation method? Do you see this as being something that can prevent or delay I e for refunds tied to those entries? Potentially, yes. That's why I'm recommending at least put those $2.32 valuation question ones where maybe if you're looking to change the value, I recommend putting those in a separate bucket for a protest or as part of, like, maybe the CAPE process. We'll have to kinda see how that how that ends up here. So I would, I wouldn't recommend that, yes, you you should continue to pursue those as you've kind of based on your own judgment. There's definitely a fair debate about how that should that should happen about how you do that valuation. And I think there's even been at least one court case filed saying, you know, customs, you've you've done your two thirty two valuations wrong on these breakouts. So all that stuff that has been happening in the last year is still gonna happen. It's just gonna the bleeding has now stopped of those valuation questions, of those, like, line breakout questions. Those are all are now resolved, at least going forward till there's something new here. Let's see here. Does the new CSMS replace the previous HCS editions to section two thirty twos? Does the latest CSMS contain all the HCS subject to section two thirty two? Yes. It does. It does contain the most updated information. And like I said, it did actually add 25 new HTS codes that weren't previously included on any list. So they kinda snuck in a few more new HTS products that we didn't know about that that had not yet been subject, but but now they are. It's a little bit limited. Yeah. It was like transformers, some cast iron parts, and some railcars were the, I think, the main the main headings indicated by these new HTS. But, yes, they were they were in there. Okay. Well, that gets through, the batch of the questions here, and that'll conclude, our webinar today. We're gonna be emailing all of you, with a link to the recording tomorrow morning, as well as a copy of the slides. So thank you so much. Have a great day. Thanks for coming.
