Section 232 Inclusion Request - Ad Hoc Coalition of Dry Van and Reefer Producers 2

A Section 232 measure is a U.S. trade action based on a finding that imports of a particular product may affect national security. The measure may impose an additional duty, quota, or another import condition. “Section 232” refers to the legal authority; the product description, tariff classification, origin rules, and any listed exclusions determine whether the measure applies.

It typically affects importers bringing covered goods into the United States, along with manufacturers, distributors, and retailers whose supply chains use those goods. The importer of record is generally responsible for declaring the merchandise correctly, paying applicable duties and fees, and meeting any reporting or documentation requirements. A product’s ordinary HTSUS classification alone may not answer the question: the importer must also review the measure’s scope, country-of-origin treatment, derivative-product rules, exclusions, and any quota or entry requirements. Customs-broker or trade-counsel review may be appropriate for difficult classifications or scope questions.

What to check

• Confirm the product’s complete and accurate HTSUS classification, including material, form, composition, and intended use; do not rely only on a supplier’s code.
• Read the measure’s product-scope language and compare it with the actual merchandise, including possible derivative articles or component-based coverage.
• Verify the country of origin and check whether the measure treats different origins, substantial transformations, or transshipments differently.
• Check the official instructions for the applicable additional duty, quota, exclusion, certification, entry-summary, and documentation requirements; do not assume a general exemption applies.
• Keep technical specifications, production records, origin documents, invoices, and any exclusion or quota documentation, and ask a customs broker or trade lawyer to review an uncertain determination.