Dear Valued Customer,

New licensing requirements for aluminum products are now set to begin Jan. 25, 2021, under a Commerce Department final rule creating a new Aluminum Import Monitoring and Analysis System. Similar to the Steel Import Monitoring and Analysis System in place since 2005, the new scheme requires importers of aluminum or their customs brokers to submit information in an online portal to obtain an automatically issued license, then submit the license number with entry summary documentation.

The new system will facilitate the monitoring of imports of aluminum articles, including monitoring for import surges.

The new system will be online at https://www.trade.gov/aluminum and will open for pre-registration on January 4, 2021, at which point Importers, brokers, and other license applicants will need to register for an account in order to create a license. Commerce will also offer a series of virtual demonstrations of the new system on that website. The Trade is advised to plan accordingly and obtain any licenses needed for entry in advance from the Commerce website. The new aluminum license system will use the same platform as the steel licensing system (SIMA), so users with an existing steel license account do not need to create new accounts.

Commerce will now require three separate data elements:
(1) the country where the largest volume of primary aluminum used in the manufacture of the imported aluminum product was smelted,
(2) the country where the second largest volume of primary aluminum used in the manufacture of the imported aluminum product was smelted; and
(3) the country where the aluminum used in the imported aluminum product was most recently cast.

The requirements apply to “basic aluminum products” under the following tariff schedule headings and subheadings:
7601, 7604, 7605, 7606, 7607, 7608, 7609, 7616.99.51.60 and 7616.99.51.70.

After registering on the new system, importers or their brokers will have to provide all the following information for each shipment prior to filing the entry summary:

  • Entry type (i.e., Consumption, Foreign-Trade Zone)
  • Importer name
  • Exporter name
  • Manufacturer name (filer may state “unknown”)
  • Country of origin
  • Country of exportation
  • Expected date of export
  • Expected date of import
  • Expected port of entry
  • Current HTS number (from Chapters 76)
  • Country where the largest volume of primary aluminum used in the manufacture of the product was smelted *
  • Country where the second largest volume of primary aluminum used in the manufacture of the product was smelted *
  • Country where the product was most recently cast
  • Quantity (kg)
  • Customs value (USD).

* Importers may say “not applicable” in this field if the product contains only secondary and no primary aluminum. Additionally, importers may say “unknown” for these fields until Dec. 23, 2021, after which they must provide the requested information.

After the form is completed in the system, the system will automatically issue an aluminum import license number. A single license can cover multiple products if certain information is the same for the shipment, or separate licenses may be required for a single shipment if that information differs. A sample copy of the proposed aluminum import license is available for viewing on Commerce’s website. The aluminum import license number obtained from Commerce for each shipment, as well as the License Type Code 28, must be reported on the corresponding entry summary or electronic equivalent in ACE.

Exemptions, modified requirements for low-value entries. No import licenses would be required on informal entries of aluminum products (i.e., entries under $2,500 that comply with other CBP requirements for informal entry.) For shipments containing less than $5,000 in aluminum, applicants would be able to apply for a reusable Low-Value License that can be used in lieu of a single-entry license for low-value entries.

FTZ entries require license. Although CBP entry is not required, Commerce would still require a license for aluminum shipped into a foreign-trade zone. The license number(s) must be reported on the FTZ admission documents and/or status designation (Customs Form 214) at the time of filing. As with steel, a separate license will not be required upon withdrawal from the FTZ.

Licenses valid for 75 days. The aluminum import licenses may be applied for up to 60 days before the expected date of importation, and until the date of filing of the entry summary. The aluminum import license is valid for up to 75 days; however, import licenses that were valid on the date of importation but expired prior to the filing of entry summary data will be accepted.

Copies must be maintained in records. There is no requirement to present physical copies of the license forms at the time of entry summary; however, copies must be maintained in accordance with CBP’s normal requirements.

Non-Confidential Data Posted on Commerce Websites
Commerce will report only “certain aggregate information” collected from license applications on an aluminum import surge monitoring website, including data on country of origin, country where the largest vol¬ume of primary aluminum used in the manufacture of the product was smelted, country where the second largest volume of primary aluminum used in the manufacture of the product was smelted, country of most recent cast, relevant aluminum product grouping, and import quantity and value.

For aluminum products shipments arriving on/before Jan 25 that are subject to the new licensing requirements, importers may wish to utilize the Estimated Entry Date to elect an entry date prior to Jan 25 to avoid the new license filing requirement on those entries.

Thank you for your attention and cooperation. If you have any questions, please contact your nearest JJB representative. Keep yourself updated with the latest industry happenings, subscribe to JJB’s Newsletters!

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