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HTS Codes Affected by New Steel and Aluminum Tariffs

Steel 580

Yesterday—March 8, 2018—President Trump signed a tariff proclamation that placed a 25% tariff on steel imports and a 10% tariff on aluminum imports from all countries except Canada and Mexico.

HTS Codes Affected

Steel Articles

  • 7206.10 through 7216.50
  • 7216.99 through 7301.10
  • 7302.10
  • 7302.40 through 7302.90
  • 7304.10 through 7306.90

Aluminum Articles

  • 7601—unwrought aluminum
  • 7604—aluminum bars, rods, and profiles
  • 7605—aluminum wire
  • 7606 and 7607—aluminum plate, sheet, strip, and foil (flat rolled products)
  • 7608 and 7609—aluminum tubes and pipes and tube and pipe fitting
  • 7616.99.51.60 and 7616.99.51.70—aluminum castings and forgings

Presidential Proclamation—Steel

Presidential Proclamation—Aluminum


No Need for Green Form for United States-Israel Exports

Shaded green, a man writes on paper.

If you export goods that qualify under the U.S.-Israel Free Trade Agreement (ILFTA), you’ll be glad to know that the hard copy certificate of origin—also known as the Green Form or Form A—has been replaced with a simple declaration, effective January 10, 2018. U.S. exporters can now prepare the declaration on either their invoice, delivery note, or on their letterhead.

We recommend that you thoroughly review the rules of origin to ensure that your goods qualify, prior to completing and signing the country of origin declaration.

Be aware that the Israeli Customs Authorities may ask you to complete a Verification Declaration to support your claim and you must retain proof of your ILFTA qualification for five years. Export.gov recommends that you keep, at least, the following information:

  • A description of the article, quantity, numbers and marks of packages, invoice numbers, and bills of lading.
  • A description of the operations performed during the production of the article in the U.S. and identification of the direct costs of processing operations.
  • A description of any material used in production of the article, which are wholly grown, produced, or manufactured in the U.S., and a statement of the cost or value of these materials.
  • A description of the operations performed on and a statement as to the origin and cost or value of any foreign (non-U.S.) materials used in the article, which are claimed to have been sufficiently processed in the U.S. making them materials produced in the U.S.
  • A description of the origin and cost or value of any foreign (non-U.S.) materials used in the article, which have not been substantially transformed in the U.S.

Below is a sample declaration that you may include on your commercial invoice or have as a separate declaration on your letterhead.

U.S. Israel Origin Invoice Declaration

I, the undersigned, hereby declare that unless otherwise indicated, the goods covered by this document fully comply with the rules of origin and the other provisions of the Agreement on the Establishment of a Free Trade Area between the Government of Israel and the Government of the United States of America.

Check one that applies:

___ The Exporter
(whether the exporter is the producer or not)

___ The Producer
(is not the exporter)

Tax Identification:





By Jim Trubits, Vice President


Why Do My Goods Need to be Marked with the Country of Origin?

Clean paint brushes labeled as made in Germany.

Receiving a marking notice from Customs and Border Protection (CBP) could cost your company a lot of money. It might result in additional expenses in trucking fees and third-party warehouse service fees to unload your cargo. Not to mention, the added cost to correct the unmarked, or inaccurately marked, merchandise. In addition, you would not be able to sell your goods until they were properly marked, which would cause delays or lost sales. Eventually, if you unmark or inaccurately mark future orders, CBP may step up exams, issue penalties, or assess a 10% marking duty on your products.

Why do my goods need to be marked?

Under Reasonable Care, CBP requires the importer to establish reliable procedures to verify that their merchandise is properly marked with the correct country of origin—upon entry—and that it matches CBP’s documents.

When do my marking obligations start?

Your responsibility begins prior to importing, as the goods must be correctly marked when they are imported into the United Sates. Therefore, it is important to give your vendors clear guidance on how to mark and label your goods, in order to meet the country of origin marking requirements.

What options do I have, if CBP discovers my goods are not marked?

You have three options.

  • Re-export the goods.
  • Destroy them.
  • Mark the goods properly using one of the CBP’s acceptable methods.

Any unmarked goods released into the commerce of the U.S. may be subjected to marking duties and penalties by CBP.

What steps should I take under Reasonable Care to prevent marking issues?

  • Work with your marketing group when they are developing new products and packaging, in addition to making changes to existing packaging.
  • Notify your vendors, in writing, of the country of origin marking requirements for the product, packaging, and Customs documentation.
  • Establish procedures to verify the correct country of origin is on the entry and Customs documents. Also, confirm the goods are properly marked when they are received at the warehouse.
  • If any errors are discovered, take immediate steps to document and correct them.

By Jim Trubits, Vice President


Increased Civil Penalties for Export Violations

A judges gavel hits a pile of money

The Department of Commerce and Department of State have increased the civil monetary penalties for export violations to account for inflation, effective January 15. It is important to recognize that these new amounts are retroactive and can be charged against each violation, regardless of when the violation occurred.

Here is a summary of the penalty increases:

  • The maximum amount for an EAR civil violation is now $295,141 or two times the value of the transaction (50 U.S.C. 1705(b)).
  • Penalties for late AES filings are now $1,360 per day; with the maximum per violation increasing to $13,605. All other AES violations are now $13,605 (13 U.S.C. 304 & 13 U.S.C. 305(b)).
  • The penalty for Directorate of Defense Trade Controls (DDTC) civil penalties has increased to $1,134,602 per violation (22 U.S.C. 2778 (e)).

The adjusted penalty amounts serve as a reminder to keep your export compliance program and training up to date. Make sure you monitor your export transactions and processes, and if you do discover an export violation, consider making a voluntary disclosure.

Contact us and ask how to we can help you build a custom export compliance program.

By Danielle Leonard


9 Most Common Medical Device Entry Screening Errors

Medical devices hung on a wall in a doctors office.

While importers of medical devices may not see the benefit of each entry line being scored through the U.S. Food and Drug Administration’s (FDA) Predictive Risk-based Evaluation for Dynamic Import Compliance Targeting (PREDICT) system, this process has the potential to help speed up entry screening of their medical devices.

What is PREDICT?

PREDICT—the FDA’s electronic screening tool for import operations—is designed to assist entry reviewers in targeting higher-risk shipments for examination. It works behind the scenes to screen all lines of imported product electronically submitted to the FDA through the U.S. Customs Automated Commercial Environment (ACE) via the Automated Broker Interface (ABI) and then assigns a score to each line. A high score means a higher risk and a low score means a low risk. If your PREDICT score is lower, the product has the potential to clear faster.

Keep Your PREDICT Score Low

Importers should ensure they provide accurate and complete data, whether they file their own entries or have a Customs Broker file for them. If there is inaccurate or missing data, such as failing to provide a device listing number or entering inaccurate product codes, your PREDICT score goes up and is flagged as high-risk. This could result in delays for present and future shipments.

How to Avoid Common Errors

The FDA has provided a list of the most common errors for medical devices in fiscal year 2017. This should help importers and entry filers identify the types of criteria they might be missing or providing incorrectly.

When in doubt, importers should use reasonable care when providing entry data. Ensuring you supply the most accurate information will help keep your PREDICT score down and result in a low-risk rating, thus expedite the screening process.

Below are the FDA’s most common entry errors for medical devices.

Most Common Entry Errors for Medical Devices in 2017

LST not transmitted
No listing number (LST) was transmitted for the entry. Verify that a listing number is required and provide one as applicable. There is no public website to search listing numbers because they are proprietary. Contact the listing entity to retrieve the number.

Could not find LST number
The listing number transmitted could not be found in FDA’s database. Verify that the listing number provided is accurate and in the correct format.

Rgstrn not trnsmttd (DEV/DFE)
No registration number was transmitted for the foreign manufacturer (DEV) or foreign device exporter (DFE). Verify that a DEV, DDM or DFE is required and provide one as applicable.

Mnfctr has Country code = US
The listing number transmitted indicated that the manufacturer was a U.S. firm, but the manufacturer provided on the line is a foreign firm. Verify the correct LST was provided.

Product Code does not match
The product code transmitted for the entry did not match the product code on file for the listing number transmitted. Verify that the correct LST was provided and/or that the product code matches the LST.

Submission # does not match
The Pre-market notification or Premarket approval (PM#) transmitted for the entry did not match one of the numbers on file for the listing number transmitted. Verify that the PM# provided matches the product being introduced for import.

Firm name does not match
The firm name provided in the entry did not match the firm name on file for the listing number transmitted. Verify that the firm listed on the entry matches the firm used for the LST.

Registration does not match
The registration number provided in the entry did not match the registration number on file for the transmitted listing number. Verify the DEV provided matches the LST provided.

UNK is declared as IUC and the AofC REG supplied instead of DEV
When the Intended Use Code (IUC) is declared as unknown (UNK), inappropriate Affirmation of Compliance (AofC) qualifiers can be transmitted causing a lookup failure. Example: AofC provided was for Drug Registration (REG) not Device Manufacturer Registration (DEV) or Device Foreign Exporter Registration (DFE) as required for a device entry. Make sure when submitting a foreign device registration number that either DEV (manufacturer) or DFE (exporter) is used. 

We understand the complexity of creating and maintaining a seamless compliance process. Contact Mohawk Global Trade Advisors to talk about how we can help you build a better Import Compliance Program.

FDA’s Medical Device Common Entry Errors.

PREDICT Fact Sheet.

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