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Trade Groups Voice Support for COAC's Calls for More Clarity on Section 232 Tariffs

Public comments submitted to the Commercial Customs Operations Advisory Committee's Jan. 14 meeting were supportive of the committee's recommendations calling for CBP to release clearer and additional guidance on how importers can comply with Section 232 tariffs (see 2601120017), particularly when it comes to the valuation of steel and aluminum content.

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Marianne Rowden, speaking on behalf of law and lobbying firm Brownstein and Hyatt, voiced support during the meeting's public comments period for the recommendation calling for CBP to clarify more generally the type and nature of documentation required to support a Section 232 tariff claim and provide information that supports valuation methodology.

She also asked if CBP could address how it would regulate the exemption under subheading 9903.81.92 for steel derivatives processed in another country from steel articles that were melted and poured in the U.S..

A representative with the United States Council for International Business said implementing the recommendations would help reduce uncertainty among businesses "that is currently undermining U.S. competitiveness. We and other like-minded associations continue to advocate for broader reforms, including restoration of the exclusion process and enhanced stakeholder consultation."

Another public comment also supported COAC's recommendations, including the one allowing importers to declare “Other than Russia” origin when importers are unable to determine the exact single country of origin but can confirm that the aluminum is not of Russian origin.

COAC members voted in favor of submitting their eight recommendations to CBP.

During the meeting, participants noted that 12 COAC members would be departing at the end of the week because their appointment terms have ended. Twenty members currently sit on the committee, which means the membership for 2026 totals eight members, for now. Each of the eight remaining members began their two-year appointment on Jan. 15, 2025.

"As we start 2026, there is much work to be done. We have a strong base of members remaining ... . When the new team members are added, there will be challenges, and with that, opportunities for solutions to ensure that the trade continues to move safely and effectively through our great nation," COAC Co-Chair Dave Corn said via written remarks. Corn is one of the departing members whose term ends this week.

CBP Commissioner Rodney Scott said CBP will seek to prioritize the selection and clearance processes for new COAC members to ensure a full committee. The agency put out a call for new members in November (see 2511180008).

In addition to receiving COAC's recommendations, Scott introduced Chris Siepmann, the new CBP Office of Trade Relations executive director. Siepmann's experience includes time in the private sector counseling industry on geopolitical risks and emerging tariff and trade policy challenges, Scott said. Siepmann also previously served as director of trade enforcement at the Office of the U.S. Trade Representative.

Kevin Salinger, the Treasury Department's deputy assistant secretary for tax policy, congratulated Siepmann, noting that he has a "big job."

"Our relationship with the trade is as important as ever, considering, among many other things, the way customs brokers are a force multiplier and a front line in protecting U.S. revenues," Salinger said.

Scott noted that CBP implemented 44 presidential trade actions in 2025 and ended the de minimis exemptions, resulting in more than $245 billion collected in tariff revenues as of Jan. 2.

"In 2026 CBP's trade priorities remain focused on the America First trade policy and finding ways to increase and strengthen domestic industry and U.S. manufacturing," Scott said. "We're going to continue to prioritize trade enforcement by deterring illegal transshipments and other forms of evasion, and we're going to hold bad actors accountable, safeguarding our supply chains to prevent dangerous and illicit goods."