Section 232 Investigations

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The Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State have announced further sanctions toward Iran by designating and placing on the Specially Designated Nationals (SDN) List a China-based supplier of graphite electrodes, 12 Iranian producers of steel and other metals products, three foreign-based sales agents of a major…

In a Federal Register interim rule to be published on December 14, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was revising certain aspects of the process for requesting exclusions from the additional duties and quantitative limitations implemented on imports of aluminum and steel under Section 232 of the…

The Office of Foreign Assets Control (OFAC) has revised Iran-related frequently asked questions (FAQs) to clarify that the sanctions authorized against the Iranian construction, mining, manufacturing and textiles sectors, among others, will not target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment, solely for use…

On December 4, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was terminating its Section 232 national security investigation into imports of mobile cranes.  The announcement notes that petitioner Manitowoc Company, Inc. requested on September 8, 2020, that its petition be withdrawn due to “a changing economic environment due…

On November 5, 2020, the United States and Mexico announced that they had concluded consultations pursuant to their Joint Statement of May 17, 2019 to address the transshipment of grain-oriented electrical steel (GOES) from outside North America into the United States through GOES-containing downstream products. The May 2019 Statement committed Mexico (and Canada) to implement…

On September 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice reopening the public comment period for its Section 232 national security investigation of imports of vanadium. BIS initially opened the investigation into vanadium imports on June 2, 2020 (see Update of June 3, 2020) as…

On September 15, 2020, the Office of the United States Trade Representative (USTR) issued a statement that it will “modify the terms of the 10% tariff imposed in August on imports of Canadian non-alloyed unwrought aluminum.” The United States will resume duty-free treatment of the Canadian aluminum retroactive to September 1, 2020, based on the…

On August 28, 2020, President Donald Trump issued a Presidential Proclamation No. 10064 to adjust U.S. imports of steel from Brazil for national security reasons. In May 2018, President Trump granted an exemption for Brazilian steel products from additional tariffs imposed under Section 232 of the Trade Expansion Act of 1962, which provides the president…

On August 21, 2020, the United States and the European Union (EU) agreed to tariff reductions on several products unrelated to ongoing trade disputes involving Section 232 national security tariffs on aluminum and steel products and retaliatory tariffs under the WTO dispute involving large commercial aircraft. In a Joint Statement issued by the Office of…