Changes to 232 Exclusion Process, and Generally Approved Exclusionss

Section 232, Trade and Tariffs

On December 14, 2020, the Bureau of Industry and Security (BIS) of the US
Department of Commerce published an interim final rule (“Interim Final Rule”) which makes changes to the process for seeking exclusions from tariffs imposed on steel (and aluminum) imports under Section 232 of the Trade Expansion Act of 1962.

The Interim Final Rule makes three key changes to the exclusion process.

First, it adds a new category of “General Approved Exclusions” (“GAEs”)
which exclude certain categories of steel products from Section 232 tariffs.

Second, it introduces a certification requirement for the quantity of steel
products that are the subject of an exclusion request.

Third, it sets the same time standard for both foreign suppliers and U.S.
objectors for which the steel product subject to an exclusion request must be
available.

You can read more specific information about the changes here.

The list of GAEs at can be found here.