Notice: Tariff Surcharge

As you may know, recently announced tariffs on various goods imported into the United States from China and Canada, and all imports of iron and steel, have now gone into effect, and more rounds of tariffs are forthcoming this week and possibly again in April. US Customs & Border Protection (CBP) manages these additional tariffs by assigning an additional HTS for each 301, 232 or IEEPA Tariff, plus an additional HTS for any applicable exclusions or quotas. Some items often require up to 5 unique HTS.

Effective immediately, the following surcharge will be effective for all imports to the United States cleared by Future Forwarding Company.

Tariff Surcharge: $3.00 per HTS after 5 HTS free per entry.

Note that this surcharge is in addition to existing entry fees, ISF, and any other handling fees.

As always, we will continue to evaluate our position as this dynamic situation continues to evolve and keep you informed of any changes. We are also committed to continuing to explore strategies to minimize the impact for your organization.

We thank you for choosing to do business with Future Forwarding Company and we value your partnership and continued support.

Implementation of Section 232 Tariffs on Steel and Aluminum Derivative Articles

As of March 11, 2025, the U.S. government has enforced Section 232 tariffs on certain derivative articles of steel and aluminum, expanding the scope of duties beyond primary metal imports. These measures aim to protect national security interests by mitigating circumvention risks associated with modified steel and aluminum products.

Understanding Derivative Articles and Their Impact

Derivative articles refer to goods that incorporate steel or aluminum as a primary component and have undergone limited processing or modification to evade direct tariff application. Common examples include:

Steel nails, tacks, and fasteners
Aluminum stranded wire, cables, and conductors
Certain types of tubing, piping, and mechanical components

The extension of tariffs to these products ensures that manufacturers and importers cannot sidestep Section 232 duties by making minor modifications to raw materials.

Compliance Challenges for Importers

The expansion of Section 232 tariffs presents challenges for importers, particularly in properly declaring derivative value for customs entry. Many derivative articles involve multi-component goods, where steel and aluminum may account for only a portion of the overall product value.

Customs valuation for these products must align with reasonable allocation of dutiable value while ensuring compliance with CBP regulations. Failure to declare accurate values may result in penalties, audits, or import delays.

Reconciliation Entry as a Temporary Reporting Mechanism

To address the complexity of derivative value reporting, importers may consider using reconciliation entry as a temporary solution. The CBP Reconciliation Program allows importers to file estimated values at the time of entry and later submit a final value adjustment. This approach provides:

Flexibility in determining the steel/aluminum proportion of a derivative article
Compliance assurance while adjusting declared values post-import
Reduced risk of penalties due to inadvertent undervaluation

Steps for Importers to Implement Reconciliation

Flag Entries for Reconciliation – When filing an entry, importers should flag it for value reconciliation in ACE (Automated Commercial Environment).
Estimate Dutiable Value – Report a preliminary steel/aluminum content value, subject to later verification.
Monitor Adjustments – Gather supporting data post-import to determine accurate derivative value.
File the Reconciliation Entry – Submit the final reconciled value within the allowed CBP timeframe to adjust Section 232 tariff obligations accordingly.

Looking Ahead

With the Section 232 tariff enforcement on derivative articles now in effect, importers should ensure proper classification of derivative articles, assess their supply chains, and utilize reconciliation entry as a strategic compliance tool.

Future regulatory developments may further refine the valuation process, but in the interim, proactive planning will help mitigate risk and ensure uninterrupted trade operations.

For more guidance on Section 232 tariff compliance and reconciliation strategies, reach out to Future Forwarding today.

USTR Seeks Public Input on Trade Measures Against China’s Maritime Dominance

The Office of the United States Trade Representative (USTR) is requesting public comments on proposed trade actions in response to China’s growing control over the global maritime, logistics, and shipbuilding industries. Following a Section 301 investigation, USTR determined that China’s policies have disadvantaged U.S. businesses and workers, prompting potential countermeasures.

Background of the Investigation

The investigation began in April 2024 after several U.S. labor unions filed a petition citing China’s long-standing efforts to dominate the shipbuilding and logistics sectors. Over the past three decades, China has significantly expanded its control, increasing its global shipbuilding market share from under 5% in 1999 to over 50% in 2023. Additionally, China now produces 95% of the world’s shipping containers and 86% of intermodal chassis, strengthening its influence over global trade logistics.

According to the USTR’s findings, China’s industrial policies have created unfair competitive conditions by displacing foreign businesses, limiting commercial opportunities, and posing economic security risks. As a result, USTR has determined that action is necessary under Section 301 of the Trade Act of 1974.

Proposed Trade Actions

To address China’s competitive advantage, the USTR is considering several measures:

Service Fees on Chinese Shipping Operators – A fee of up to $1,000,000 per vessel entry into U.S. ports for operators with Chinese-built vessels.
Tariffs on Operators Using Chinese-Built Ships – Additional fees for companies that operate or have pending orders for Chinese-manufactured vessels.
Incentives for U.S.-Built Vessels – A system of fee reimbursements for operators using U.S.-manufactured ships.
Shipping Restrictions on U.S. Exports – A phased-in requirement that a portion of U.S. goods be transported on U.S.-flagged and U.S.-built vessels.
Security Measures Against Chinese Logistics Platforms – Possible restrictions on the use of LOGINK, a Chinese-developed logistics data platform, due to security concerns.

Public Comment Period and Hearing Details

The USTR is encouraging stakeholders to provide feedback on these proposed actions. The key deadlines are as follows:

February 21, 2025 – Public comment period opens.
March 10, 2025 – Deadline to request participation in the public hearing.
March 24, 2025 – Deadline to submit written comments.
March 24, 2025 – Public hearing at the U.S. International Trade Commission in Washington, D.C.
Seven days after the hearing – Deadline for post-hearing rebuttal comments.

Comments and requests to participate in the hearing can be submitted via USTR’s online portal at https://comments.ustr.gov/s/ using docket numbers USTR–2025–0002 (for written comments) and USTR–2025–0003(for hearing requests).

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