Aluminum Onshoring Relief + 4 More Analyses
These five pieces belong in different operating files. Open the one that changes your HTS scope, bond model, capital horizon, or Section 232 product record.
Good morning. Yesterday, the analysis desk published five reads on aluminum relief, Canadian product scope, bond sizing, USMCA capital planning, and derivative coverage. Start with the one tied to an entry, sourcing decision, or investment case.
The July 20 proclamation ties annual half-rate primary aluminum imports to an approved U.S. onshoring plan and anticipated completed-project output. Commerce has not yet issued the public application and entry mechanics. Companies should prepare a joint project and customs record.
Read the analysis: Section 232 Aluminum Onshoring Relief Turns on the Company File.
New U.S. Section 338 duties on selected Canadian products use three separate Chapter 99 headings under shared U.S. Note 51. USMCA origin may still determine the base rate, but it does not by itself remove the additional 50% for a listed product. Import teams should map HTS scope before the August 19 entry date.
Read the analysis: Canada Section 338 Tariffs Put HTS Scope Ahead of USMCA.
Section 122 ends prospective assessments after the July 24 cutoff, but qualifying duties can remain in the preceding 12-month data used for CBP's bond review. Importers should model the runout before requesting a replacement bond.
Read the analysis: Section 122 Tariff Expiration Does Not Reset Your Customs Bond.
Capital projects approved in 2026 can carry payback, contract, and residual-value assumptions across USMCA's scheduled July 1, 2036 term boundary. Because the July review did not produce a unanimous extension, projects with policy-sensitive value after that date should run a separate horizon case.
Read the analysis: USMCA's 2036 Boundary Is Already Inside Capital Budgets.
Section 232 derivative coverage can expand before the planned 2027 rules because Proclamation 11021 authorizes joint Commerce-USTR findings. If they make such a finding, a Federal Register notice would set the covered entry date. Importers should keep a notice-ready product file.
Read the analysis: Section 232 Derivative Scope Can Expand Before the 2027 Rules.