The U.S. Bureau of Industry and Security (BIS) issued a reminder to all users of the Steel and Aluminum Section 232 Exclusion Portal to review the text and closely follow the December 14, 2020, Interim Final Rule guidelines on the 232 Exclusions Process.
This includes users who are exclusion requestors, as well as objectors.
Of note, BIS highlighted:
- New Word Count Limit for Attachments: 5,000 words for Supplements, Exclusion Requests and Objections; and 2,500 words for Rebuttals and Surrebuttals.
- Requestors May Now File Single Exclusion Requests for a Range of Product Dimensions provided that the specified range falls within the minimum and/or maximum range of dimensions specified by the relevant Harmonized Tariff Schedule (HTS) Classification.
- Objectors May Now Object to Part of the Specified Product Range in an Exclusion Request even if it covers only part of the specified range of product dimensions submitted in an Exclusion Request.
- Parties Must Provide Public Summary of Confidential Business Information
- Objectors No Longer Must Produce and Provide the Requested Product in Eight Weeks, so long as they provide within a timeframe equal to or less than that of the delivery timeframe of the foreign supplier cited in the Exclusion Request.
- New Certification Requirements applicable to all Exclusion Requests filed on or after December 14, 2020.
Failure to adhere to guidelines or fully provide the required information may negatively impact the ultimate determination regarding an Exclusion Request or Objection.
Questions regarding Section 232 and their exclusions may be directed to your Livingston account manager.