Media sources are reporting the Department of Commerce will not consider steel and aluminum product exclusions for countries subject to quotas. Only countries facing the tariffs will be considered for product exclusions.

Currently, South Korea, Brazil, and Argentina have agreed to an absolute quota deal on certain steel products that are subject to the Section 232 tariffs.

The steel quotas are separated into 54 subcategories for South Korea, Argentina, and Brazil. Argentina has already reached its absolute quota for 40 of the 54 subcategories, while 18 subcategories have been filled for Brazil, and 9 have been filled for South Korea.

As of June 1, 2018, all countries of origin except Argentina and Australia are subject to the 10 percent tariff on aluminum products. Argentina agreed to cap exports of aluminum at 100 percent of the average exports to the U.S. over the last 3 years. The absolute quota is divided into two subcategories, equaling over 180,000 short tons per year.

Once a country reaches its quota for the quota period no entry for consumption of the product will be permitted.

Australia is currently the only country to have maintained a country-based exemption without having agreed to a quota regime.

 

 

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Photo of Alexander H. Schaefer Alexander H. Schaefer

Alexander H. Schaefer is a partner in the International Trade Group at the firm’s Washington, D.C. office. Alex represents clients contending with U.S. import regulations, including the customs and trade remedies laws. He assists clients with a broad range of Customs issues, including

Alexander H. Schaefer is a partner in the International Trade Group at the firm’s Washington, D.C. office. Alex represents clients contending with U.S. import regulations, including the customs and trade remedies laws. He assists clients with a broad range of Customs issues, including tariff classification, import valuation, focused assessment audits, penalty proceedings, prior disclosures, reconciliation, special duty programs, and free trade agreements. In addition, Alex has represented both petitioners and respondents in a variety of trade remedy cases, including antidumping, countervailing duty, and Section 201 proceedings before the U.S. Department of Commerce, the U.S. International Trade Commission, the U.S. Court of International Trade, and the U.S. Court of Appeals for the Federal Circuit.

Alex is a member of the International Trade Group’s duty recovery team, which helps companies identify opportunities to minimize import duty outlays and cut supply chain costs to increase profitability. Alex also works closely with the firm’s Product Risk Management Group, which helps clients in a broad range of industries identify potential legal risks associated with new products and ventures as well as providing advice on risk management tactics and protocols.

Alex is a member of the bars of the Commonwealth of Virginia and the District of Columbia.

Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.