Steel and aluminum: managing origin, tariffs and compliance in U.S. trade
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This presentation looks at how US Section 232 tariffs on steel and aluminium, and the new "melt and pour" origin requirement, are creating fresh compliance obligations for exporters and their trade compliance teams.
Topics covered:
- What Section 232 covers and the extra duties (up to 50%) it allows on products made of, or containing, steel and aluminium
- The August 2025 expansion adding 753 customs codes to the regulation's scope
- The new "melt and pour" origin declaration, separate from standard preferential/non-preferential origin, and why it can differ from substantial-transformation origin
- Practical and system challenges: ERP systems not built to capture melt-and-pour data, and the two-line invoicing requirement for product and steel-content value
- Why suppliers are not legally obliged to disclose melt-and-pour origin, and how to secure this contractually through sourcing-contract clauses
- The EU's planned equivalent regime around 2026, referencing the EU steel and metal action plan and the EU-US joint statement
- Recommended company actions: impact assessment, supply chain mapping, contractual clauses, and ERP-based traceability
- The tension between the EU's Omnibus package (reducing administrative burden) and new third-country compliance obligations
For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.
Please note that this summary was generated using AI, based on the recording and available slides.
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