Customs and Trade Policy Developments We’re Following This Month

To help you better prepare for what’s coming, here’s a rundown of the customs and trade developments we’re following this month:

Section 232 aluminum smelt and cast requirements

U.S. Customs and Border Protection (CBP) issued updated guidance for Section 232 Aluminum Smelt and Cast Requirements in CSMS #55438432 following the announcement of the 200% tariff on Russian aluminum and derivatives (effective March 10, 2023) and on aluminum imports with any amount of primary aluminum smelted or cast in Russia (effective April 20, 2023).

Starting April 10, 2023, importers will be required to provide the following details on aluminum imports from all countries.

  1. Primary Country of Smelt
  2. The country where the largest volume of new aluminum metal is produced from aluminum oxide (alumina) by the electrolytic Hall-Heroult process.

  3. Secondary Country of Smelt 
  4. The country where the second largest volume of new aluminum metal is produced from aluminum oxide (alumina) by the electrolytic Hall-Heroult process. 

    If Russia is not the primary country of smelt reported, and any primary aluminum used in the manufacture of the product was smelted in Russia, then Russia must be reported as the secondary country of smelt.

    If a product contains only secondary aluminum and no primary aluminum, then filers should report “N/A” for the primary and secondary country of smelt. Secondary aluminum is aluminum metal produced from recycled aluminum scrap through a re-melting process. 

  5. Country of Cast
  6. The country where the aluminum was last liquified by heat and cast into a solid state. The final solid state can take the form of either a semi-finished product or a finished aluminum product.

    Products of the United States are exempt from smelt and cast reporting requirements. The country of smelt should be reported as “N/A” and the country of cast should be reported as the United States until further notice.

  7. Foreign Trade Zones
  8. The smelt and cast reporting requirements also apply to products withdrawn from a Foreign Trade Zone (FTZ) for consumption, on or after 12:01 a.m. eastern daylight time on April 10, 2023.

    For a list of aluminum article and derivative aluminum article products covered please visit CBP’s Trade Remedies page or Federal Register Notice.

Uyghur Forced Labor Prevention Act Region Alert starts this week

In preparation for the start of the Uyghur Forced Labor Prevention Act (UFLPA) Region Alert Enhancement deploying March 18, 2023, CBP posted a frequently asked questions document for the trade.

The enhancement requires a postal code for parties based in China when the country of origin is China. If the product is a textile item or subject to a partner government agency (PGA) requiring the actual manufacturer of the goods be declared, then the manufacturer name, address, and valid postal code is required. If the product does not require an actual manufacturer to be declared then the name, address, and valid postal code of the invoicing party should be declared. 

If an invalid Chinese postal code, or no postal code is provided, an error message will be sent to the filer. A warning message will be sent to filers when a Xinjiang Uyghur Autonomous Region (XUAR) postal code is provided. CBP advised they will not publish a list of impacted postal codes. An UFLPA Entity List has been provided and should be reviewed by importers as part of their due diligence. For more information and resources please see our Client Advisory issued earlier this year.

ACE Portal modernization update

On March 4, 2023, CBP deployed the latest update to the ACE Portal Modernization, giving account owners the ability to hide employee social security numbers (SSN) and organization Tax ID numbers from users with read-only account access. For instructions on how to mask personal identifiable information (PII) in the ACE Secure Data Portal (ACE Portal) CBP linked to this Quick Reference Card. Additional details on the modernization strategies can be located on the ACE Portal Modernization page.

Customs Broker License Exam

The next Customs Broker License Exam (CBLE) will take place on April 26, 2023. Registration is open and there is a webinar on March 21, 2023, for a limited number of remote proctored exam registrants, available on a first-come, first-served basis. The CBLE will also be available in-person. For details on the CBLE, reference materials recommended, and registration details, visit the CBLE site

April National Commodity Specialist Division webinars

CSMS# 55418078 was issued March 9, 2023, notifying that registration is open for the April National Commodity Specialist Division (NCSD) webinars. There are 35 commodity-specific educational webinars scheduled for 2023 and CBP will announce the registration opening for each month via the Cargo Systems Messaging Service (CSMS). Links to each registration can be found on CBP's Trade Outreach Webinar site

April webinars include:

  • April 4, 2023: Heading 2711 Petroleum Gasses and Other Gaseous Hydrocarbons
  • April 11, 2023: Back to Basics: What is a Men’s T-Shirt? And What isn’t a Men’s T-shirt?

Section 321 data pilot expands

CBP is accepting new applicants to participate in the Section 321 Data Pilot scheduled to run through August 2025. The pilot opened in August 2019 with the goal of gathering advance data from ecommerce supply chain partners to test risk advantages. The pilot has resulted in fewer CBP holds for pilot participants and makes risk evaluations for CBP faster and more accurate. For details on participating in the Section 321 data pilot, visit the Section 321 data pilot Federal Register Notice issued February 16, 2023 or discuss with your C.H. Robinson representative.

Stay informed

Developments in customs and trade continue to evolve—stay informed to be prepared:


Jessica Woltering
Manager, Compliance
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