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Presidential Proclamation 10064 (28 August 2020) converted the Section 232 25% tariff on Brazilian and Argentine steel — which had been in place since Proclamation 9705 (2018) — into an absolute quantitative limitation (quota), effective immediately. The abrupt switch created a contractual trap: US manufacturers that had signed supply agreements with Brazilian mills before 28 August 2020, expecting tariff treatment, now faced quota fill-out and potential import suspension mid-delivery cycle.
BIS responded on 13 October 2020 with this temporary final rule, published at 15 CFR Supplement No. 1 to Part 705, opening a narrow administrative relief channel. An importer (or US producer receiving the steel) may submit a sworn certification to steel232-exp@bis.doc.gov attesting that all four criteria are met:
1. Contract for production of the covered Brazilian steel articles was executed before 28 August 2020. 2. The contract specifies the quantity of steel and a shipment date no later than 31 December 2020. 3. The steel is intended for use in the United States. 4. The steel cannot be procured from an alternative domestic or non-Brazilian supplier to meet the necessary technical specifications and delivery schedule without significant disruption to US production activity.
Approved certifications allowed quota-exempt entry of the contracted volumes through 31 December 2020. The rule carried no standing appropriation and expired automatically at year-end with the quota period.
holders caught at the tariff-to-quota transition; it set no ongoing precedent for quota exclusions.
from Brazil under HTS Chapter 73 basket headings) remained in force through subsequent administrations and were reaffirmed in the 2025 quota renewal cycle.
standing BIS contact point for Section 232 steel allocation inquiries.
quota substitution is not yet filed in the IPTM register — a backfill candidate as the foundational parent action for this relief rule.