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On June 29, 2026, U.S. Customs and Border Protection (CBP) released CSMS # 69087399, providing guidance for the import adjustment offset program applicable to Section 232 duties on automobile and medium and heavy-duty vehicle (MHDV) parts. We summarize below the latest guidance from CBP and procedural steps for claiming offsets against Section 232 duties.

Eligibility and Tracking Limits: The duty offset is not a blanket exemption; rather, it may only be claimed by importers who have been specifically granted an offset license by the Department of Commerce (DOC), and only up to the amount authorized under that license. Pursuant to the guidance, importers are advised to track their usage using TR-015 report in Automated Commercial Environment (ACE), as exceeding the granted offset amount will render them liable for Section 232 duties and potential penalty actions under 19 U.S.C. § 1592.

ACE Filing Procedures: To successfully claim the offset in ACE, importers must follow the following procedures:

  • Chapter 99 HTSUS Codes: File the applicable Chapter 99 HTSUS codes with a zero (0) duty amount. For automobile parts, use tariff classification number 9903.94.05 or 9903.94.07. For MHDV parts, use 9903.74.08 or 9903.74.09.
  • Column One Duties: Concurrently, file the standard column one duty amount for the corresponding Chapter 1 – 97 HTSUS when the license number is submitted on the entry summary line.
  • Chapter 98 Exemptions: If submitting special classifications under Chapter 98 (9802.00.40, 9802.00.50, 9802.00.60 or 9802.00.80) on the same entry line, file a zero (0) duty amount for those as well.
  • License Formatting: The DOC provided 8-character offset license number (AANNNNNN) (two letters followed by six numbers) must be submitted in the Importer Additional Declaration Field (54 record) using Type Code 11 (Offset License) on the entry summary data. 

Country Specific Calculation Rules: Special calculation rules apply to automobile parts originating from Japan, the United Kingdom, European Union member countries, South Korea and Taiwan. For imports from these countries, the offset can only apply to the specific portion of the tariff assessed under Section 232, which is calculated as the difference between the total combined tariff and the standard column one rate.  In other words, the offset only applies to Section 232 duties and not the underlying Column 1 duty.  Additionally, imports from these countries must use the following:

  • Chapter 99 HTSUS Codes: File the applicable Chapter 99 HTSUS codes with a zero (0) duty amount. Importers must use a designated set of tariff classifications under 9903.94.43, 9903.94.55, 9903.94.32, 9903.94.33, 9903.94.53, 9903.94.45, 9903.94.63, 9903.94.65, 9903.94.67, or 9903.94.69.
  • Column One Duties: File the standard column one duty amount for the corresponding Chapter 1 – 97 HTSUS when the license number is submitted on the entry summary line.

Post Summary Correction: Importers who have already paid Section 232 duties on eligible entries can submit a PSC to amend previous entries and credit those paid duties against their authorized offset license.

Exemptions: Note that filing the Chapter 99 HTSUS with the offset license number automatically exempts the imported parts from other Section 232 metals or wood duties.

 The Husch Blackwell International Trade and Supply Chain team will continue to monitor this and provide updates as they become available. If you have any questions or concerns, please contact your Husch Blackwell attorney.

Tags: ACE filing requirements, CBP, CSMS 69087399, European Union, Japan, medium and heavy-duty vehicle parts, MHDV, South Korea, Taiwan, United Kingdom
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Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

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Photo of Cortney Morgan Cortney Morgan

An experienced attorney in the area of international trade and supply chain issues, Cortney advises foreign and domestic clients on all aspects of international trade regulation, planning and compliance, including import (customs), export controls, economic sanctions, embargoes, international trade agreements and preference programs.

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Photo of Beau Jackson Beau Jackson

Beau leads Husch Blackwell’s Section 337 practice, and assists clients with a variety of other international business issues. His practice focuses on trade and intellectual property disputes, with significant experience litigating Section 337 cases before the U.S. International Trade Commission (ITC).

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Photo of Moushami Joshi Moushami Joshi

Moushami draws on an international background and career to advise clients on tariffs, customs matters, and trade remedies. She has represented foreign governments and multinational corporations in all aspects of customs and tariff related matters. She has represented clients in safeguard, antidumping, and

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Moushami draws on an international background and career to advise clients on tariffs, customs matters, and trade remedies. She has represented foreign governments and multinational corporations in all aspects of customs and tariff related matters. She has represented clients in safeguard, antidumping, and countervailing duty actions before the Department of Commerce and U.S. International Trade Commission and in appeals before the Court of International Trade and the Court of Appeals for the Federal Circuit, as well as before NAFTA and USMCA panels. Moushami regularly advises clients on tariffs and customs rules, including Section 301 and 232 tariffs and exclusion processes, customs classifications, country of origin marking requirements, prior disclosures, relief petitions, and protests. She is especially knowledgeable about Buy America and “Made in U.S.A.” rules and their implications for clients in various industries.

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Photo of Bilal Hassan Bilal Hassan

Bilal’s practice focuses on U.S. customs and import compliance matters, complemented by broad experience in export controls. He regularly advises clients on complex regulatory issues before key U.S. administrative agencies, including U.S. Customs and Border Protection (CPB), the Department of Commerce (DOC), the…

Bilal’s practice focuses on U.S. customs and import compliance matters, complemented by broad experience in export controls. He regularly advises clients on complex regulatory issues before key U.S. administrative agencies, including U.S. Customs and Border Protection (CPB), the Department of Commerce (DOC), the Department of Homeland Security (DHS), and the Bureau of Industry and Security (BIS).

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