CBP Requests Comments on Form 7501 for Steel and Aluminum Imports

May 05, 2023

All merchandise imported into the commerce of the United States must be accompanied by a Form 7501 Entry Summary. At present, Form 7501 contains fields to report the country of origin and the exporting country of imported merchandise. CBP is seeking comments on a proposed revision to Form 7501 that would collect additional information on certain imports of steel and aluminum.

Steel: CBP has proposed adding a data field to Form 7501 to identify the country where the steel used in the manufacture of the product was melted and poured. CBP considers the country of melt and pour to be the original location where the raw steel is first produced in a steel-making furnace in a liquid state; and then poured into its first solid shape.

Aluminum: CBP has proposed adding data fields to Form 7501 to collect two types of information. First, importers would report the countries where the largest and second largest volume of primary aluminum used in the manufacture of the imported aluminum product was smelted on the Form 7501. These fields would apply to the country where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process. Second, importers would report the country where the aluminum used in the imported aluminum product was most recently cast on the Form 7501.

CBP’s proposed changes to Form 7501 would incorporate information already being collected pursuant to the U.S. Department of Commerce’s import licensing requirements. Import license applications are used by Commerce to monitor anticipated imports of certain aluminum and steel products into the United States. On the license application, importers must identify the country of melt and pour for steel imports and the country of smelt and cast for aluminum imports. This requirement exists as a result of the United States-Mexico-Canada Agreement and the anti-surge requirements in that agreement to remove Section 232 measures on steel and aluminum imports from Canada and Mexico.

Parties have until June 20, 2023, to submit comments. All comments will be made publicly available. CBP has requested comments that address at least one of the following four topics:

  1. Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;
  2. The accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
  3. Suggestions to enhance the quality, utility, and clarity of the information to be collected; and
  4. Suggestions to minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses.

Firms and companies in the steel and aluminum industries should strongly consider filing comments with CBP to advise on the nature and availability of this information. Steel and aluminum traceability is a critical component to fair trade enforcement and anti-evasion efforts.

Comments can be filed at regulations.gov under docket number 1651-0022.

The Federal Register notice can be found here.