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Leibowitz on Trade: Final Annexes Released on Proclamation Covering “Derivatives”
Written by Lewis Leibowitz
January 29, 2020
Trade attorney and Steel Market Update contributor Lewis Leibowitz offers the following update on events in Washington:
The presidential proclamation announcing new tariffs on “derivative” steel and aluminum articles was published in the Jan. 29 Federal Register (85 Fed. Reg. 5281). There are two Annexes that detail the products covered by the new tariffs:
1. “Aluminum (Annex 1):
(A) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.10.50);
(B) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing comprising electrical conductors, riot fitted with fittings or made up into articles (described in subheading 7614.90.20);
(C) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing not comprising electrical conductors, not fitted with fittings or made up into articles (described in subheading 7614.90.40);
(D) stranded wire, cables, plaited bands and the like, including slings and similar articles, of aluminum and not with steel core, not electrically insulated; the foregoing fitted with fittings or made up into articles (described in subheading 7614.90.50);
(E) bumper stampings of aluminum, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30) ; and
(F) body stampings of aluminum, for tractors suitable for agricultural use (described in subheading 8708.29.21).”
2. “Steel (Annex 2):
(A) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), suitable for use in power-actuated handtools, threaded (described in subheading 7317.00.30); and
(B) nails, tacks (other than thumb tacks), drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material (excluding such articles with heads of copper), of one piece construction, whether or not made of round wire; the foregoing described in statistical reporting numbers 7317.00.5503, 7317.00.5505, 7317.00.5507, 7317.00.5560, 7317.00.5580 or 7317.00.6560 only and not in other statistical reporting numbers of subheadings 7317.00.55 and 7317.00.65;
(C) bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30); and
(D) body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).”
These product descriptions should be read in conjunction with the tariff reporting numbers cited in the Annexes. The 10-digit tariff numbers may include products that are not within the verbal descriptions above. As I read the notice, only products classified in these tariff numbers and described verbally would be subject to the new tariffs.
There are other provisions in the Annexes that describe the workings of the new tariffs, which I will report on later. Please note that automotive stampings covered by the Annexes are only bumper stampings, not body stampings. Body stampings for tractors are covered, but not body stampings for other motor vehicles.
Lewis Leibowitz
The Law Office of Lewis E. Leibowitz
1400 16th Street, N.W.
Suite 350
Washington, D.C. 20036
Phone: (202) 776-1142
Fax: (202) 861-2924
Cell: (202) 250-1551
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Lewis Leibowitz
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