The International Trade Administration issues a final rule on aluminum products that will require an import license

Last week, the Department of Commerce and International Trade Administration (ITA) issued a final rule that will impact the importing of aluminum products effective January 25, 2021. Most imports of aluminum products will require the submission of an import license prior to the entry submitted to US Customs.

The ITA system known as “AIM” will be operational on January 4, 2021. Therefore, license applicants will be able to obtain their user identification numbers and apply for licenses beginning on January 4, 2021. Licenses will be required for mostly all aluminum imports on or after January 25, 2021, but there are some minor exceptions to this final rule.

The final rule requires 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.

Foreign Trade Zone Admissions, all shipments of covered aluminum products into foreign trade zone (FTZ), known as FTZ admissions, will require an aluminum import license prior to the filing of FTZ admission documents. The license number(s) must be reported on the FTZ admission documents and/or status designation (Customs Form 214) at the time of filing.

After registering on the new system, the applicant will have to provide the following information for each shipment prior to filing the entry summary:

  • Filer company name and address
  • Filer contact name, phone number, fax number and email address
  • 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 (in kilograms)
  • Customs value (in U.S. $ amount


Timeframe to manage this new requirement

The aluminum import license can be applied for up to 60 days prior to the expected date of import and until the date of filing of the CBP entry summary documents, or its electronic equivalent. The aluminum import license is valid for up to 75 days.

Exceptions to this final rule

Aluminum import licenses are not required on temporary importation bond (TIB) entries, transportation, and exportation (T&E) entries, or entries into a bonded warehouse. Covered aluminum products withdrawn for consumption from a bonded warehouse will require a license at the entry summary.

However, copies must be kept in accordance with normal Customs record keeping regulations. No import license shall be required on informal entries of covered aluminum products, such as merchandise valued at less than $2,500.

This exemption applies to informal entries only; imports of aluminum valued at less than $2,500 that are part of a formal entry will require a license.

For shipments containing less than $5,000 worth of aluminum, applicants can apply for a reusable low-value license.

Commerce will maintain an import monitoring system on the public AIM system website that will report certain aggregate information on imports of aluminum products obtained from the aluminum licenses and, where available, from publicly available U.S. import statistics. Aggregate data will be reported, as appropriate, on a monthly basis by country of origin, country of smelt, country of last cast, relevant aluminum product grouping, etc., and will include import quantity (metric tons), import Customs value (U.S. $), and average unit value ($/metric ton). The website will also contain certain aggregate data at the 6-digit Harmonized Tariff Schedule level and will also present a range of historical data for comparison purposes.

To review the full details of the final rule please see the link to the Federal Register announcement, and of course, if you need any assistance with understanding this change in regulations please do not hesitate to reach out to me.