DAILY TRADE NEWS ·
Drone Section 232 Tariffs Start as HTS Revision 18 Goes Live

The new U.S. Section 232 duties on unmanned aircraft systems and specified components are now live. USITC published 2026 HTS Revision 18 on September 2, and CBP followed with CSMS #69738151. For covered entries made on or after 12:01 a.m. EDT on September 3, filers must pair the ordinary Chapter 85 or 88 classification with the applicable new Chapter 99 heading.
Also new in this reporting window: OFAC expanded three Venezuela general licenses to cover coal and Carbozulia; Commerce imposed a preliminary 10.17% countervailing-duty deposit on Austrian oil-country tubular goods; and final review rates changed for heavy-walled rectangular pipe from Mexico. The Commission is also reviewing a Samsung mobile-device patent determination, but has not issued an exclusion order.
CBP activates the drone Section 232 filing architecture
Proclamation 11055 · HTS Revision 18 · CSMS #69738151 issued September 2 at 3:07 p.m. EDT
The new measure applies to covered unmanned aircraft systems, docking stations and critical components entered for consumption—or withdrawn from warehouse for consumption—on or after 12:01 a.m. EDT on September 3, 2026. CBP directs filers to report the ordinary Chapter 85 or 88 classification and one applicable heading from 9903.08.20 through 9903.08.26. CBP implementation instructions.
| Heading | Current treatment | Typical use | Filing status |
|---|---|---|---|
| 9903.08.20 | 0% additional duty | Enumerated tariff lines that meet the note’s non-covered or non-UAS-use conditions. | Available when the complete note conditions are satisfied. |
| 9903.08.21 | 100% additional duty | Specified docking stations and critical components; larger covered UAS and parts; and covered UAS with thermal imaging. | Report now for qualifying entries. |
| 9903.08.22 | 25% additional duty | Covered smaller UAS without thermal imaging. From February 9, 2027, the heading expands to specified UAS parts not already assigned to the 100% category. | Report now for qualifying entries. |
| 9903.08.25 | 0% additional duty | Qualifying UAS and components covered by an approved Department of Homeland Security or Department of War onshoring plan. | Available now; this heading expires February 9, 2027. |
| 9903.08.23, .24, .26 | Partner-country or Commerce-approved onshoring treatment | United Kingdom; listed trade-agreement partners; or an approved Commerce onshoring plan. | Do not report until CBP issues further guidance. |
Classification, FTZ and drawback controls
- Covered merchandise may remain subject to antidumping, countervailing and other applicable duties; a free-trade preference does not by itself remove the Section 232 duty.
- Covered goods admitted to a U.S. foreign-trade zone generally must enter in privileged foreign status, except where the proclamation provides otherwise.
- Manufacturing drawback is narrowly available only under 19 U.S.C. 1313(a) or (b), for qualifying non-AD/CVD duties and trade-agreement-partner products meeting the proclamation’s content test. Review the legal conditions before claiming.
The tariff scope includes selected lines in Chapters 85, 88 and 99. The two highest-risk operational distinctions are whether a smaller UAS includes thermal imaging and whether a part is for a covered larger UAS. Product function, end use and technical documentation therefore matter alongside the ten-digit HTS number. Proclamation 11055 and annex.
Revision 18 also incorporates the beef quota expansion and China 301 amendments
2026 HTS Revision 18 · Published September 2, 2026
USITC’s new revision adds eight drone headings, 9903.54.02 for the temporary lean-beef quota increase, and the statistical-number amendments to four existing China Section 301 exclusions. These are now reflected in the current electronic HTS. USITC HTS archive.
Beef: a larger quota, not a new duty rate
Heading 9903.54.02 implements the previously announced temporary addition of 300,000 metric tons of specified lean-beef trimmings from “other countries or areas,” covering statistical reporting numbers 0201.30.5091, 0201.30.5097, 0202.30.5091 and 0202.30.5097. The three 100,000-metric-ton tranches open in September, October and the October 31–November 30 period. The underlying rates do not change. CBP quota bulletin QB 26-230.
China 301: statistical alignment, not a new exclusion
Revision 18 also embeds USTR’s conforming amendments for four existing product exclusions, effective for entries on or after July 1. The revised references cover successor reporting numbers in 8413.91.90 and 3926.90.99. The change preserves existing product coverage; it does not create a new exclusion, extend one or reduce a Section 301 rate. Separate CBP entry guidance remains pending. USTR notice, 91 FR 56538.
OFAC adds coal and Carbozulia to three general-license frameworks
General Licenses 51D, 54C and 55A · Issued September 2, 2026
OFAC replaced three earlier licenses and expressly added Venezuelan-origin coal and transactions involving Carbozulia to defined minerals-related authorizations. The revisions are not blanket sanctions relief: each license has different eligible parties, activity boundaries, payment conditions, reporting requirements and excluded counterparties. OFAC release page.
| License | What it can authorize | Key boundary | Reporting |
|---|---|---|---|
| GL 51D | Defined export, sale, purchase, storage, delivery and transport transactions involving Venezuelan-origin coal or minerals, including gold, by eligible established U.S. entities. | Does not authorize mining or extraction in Venezuela; payment and counterparty restrictions apply. | Initial report within 10 days after the first transaction, then every 30 days. |
| GL 54C | Defined U.S. goods, technology, software and services supporting exploration, development, mining, processing, refining or production of covered coal and minerals. | Does not authorize a new joint venture or equity investment; sanctions-country and blocked-party limits remain. | Initial report within 10 days after the first transaction, then every 90 days. |
| GL 55A | Due diligence and negotiation or entry into contingent contracts for potential new investment in covered coal, minerals and gold activities. | Performance under the contingent contract is not authorized without separate OFAC authorization. | Follow the license terms and retain the diligence record; do not treat negotiation authority as operating authority. |
GL 51D and GL 54C also prescribe where certain payments involving blocked Venezuelan persons must be placed, and the licenses retain restrictions involving Russia, Iran, North Korea, Cuba, specified China-related participation, blocked vessels and other blocked property. Review beneficial ownership and payment routing before relying on a license. GL 51D · GL 54C · GL 55A.
New deposit instructions affect Austrian OCTG and Mexican heavy-walled pipe
Austria OCTG: preliminary 10.17% countervailing-duty deposit
Commerce preliminarily found a 10.17% countervailable subsidy rate for voestalpine Tubulars GmbH & Co KG and all other Austrian producers/exporters of subject oil-country tubular goods. CBP is directed to suspend liquidation and collect cash deposits at 10.17% for subject entries made on or after September 3. This is a preliminary CVD determination, not the companion antidumping result; the aligned final determination is currently due January 12, 2027 unless the schedule changes. Commerce preliminary determination.
Mexico heavy-walled rectangular pipe: final review rates take effect
For entries on or after September 3, the final 2023–2024 administrative-review cash-deposit rates are 31.23% for Forza Steel, S.A. de C.V., 7.45% for Productos Laminados de Monterrey S.A. de C.V., and 16.84% for five named non-examined companies. The order’s all-others rate remains 4.91% for firms without a more specific completed-segment rate. Assessment of review-period entries follows separate importer-specific instructions. Commerce final results.
USITC reviews the Samsung mobile-device patent determination
Investigation 337-TA-1432 · Commission notice published September 3
The Commission will review portions of the administrative law judge’s final initial determination in Maxell’s case involving specified Samsung mobile devices. It requested briefing on infringement, domestic-industry issues, remedy, the public interest and bonding. An ALJ recommendation is not an import ban: the Commission has not yet issued a limited exclusion order or cease-and-desist order. Importers should preserve model and patent-feature mapping while the review is pending. Commission review notice.
Actions for trade and compliance teams
- Load HTS Revision 18 before filing September 3 entries. Confirm the broker, ERP and screening tables contain 9903.08.20–9903.08.26 and 9903.54.02.
- Create a UAS decision tree. Capture platform weight, thermal-imaging capability, docking-station/component function, end use, origin and any approved onshoring plan.
- Block premature partner headings. Configure 9903.08.23, 9903.08.24 and 9903.08.26 as “await CBP instruction,” not as self-service rate choices.
- Review FTZ and drawback assumptions. Flag covered zone admissions for privileged foreign status and require legal review before any manufacturing-drawback claim.
- Re-paper Venezuela activity. Match each activity to GL 51D, 54C or 55A, screen ownership and vessels, validate payment routing, and calendar the applicable 10-day and recurring reports.
- Update AD/CVD matrices. Apply the Austria CVD and Mexico AD rates only to in-scope merchandise and the correct exporter/producer combination.
What to watch
- CBP follow-up for 9903.08.23, .24 and .26: the next message should resolve when and how partner-country and Commerce-plan headings may be transmitted.
- February 9, 2027 UAS transition: specified parts move into the 25% structure and temporary heading 9903.08.25 expires.
- China 301 entry mechanics: USTR says CBP will issue separate instructions for the July 1 statistical-number amendments.
- Austria OCTG final phase: monitor the companion AD/CVD schedule and any postponement before the currently aligned January 12, 2027 final date.
- Investigation 337-TA-1432: watch for the Commission’s final violation and remedy decision before treating any Samsung model as excluded.
Questions and answers
Are all imported drones now subject to a 100% additional duty?
No. The treatment depends on the product, size/use conditions, component category, thermal-imaging capability, origin and any qualifying onshoring plan. Covered smaller UAS without thermal imaging generally fall under the 25% heading, while specified thermal-imaging systems, larger UAS and critical components can fall under the 100% heading.
Can filers use the partner-country headings now?
Not yet for 9903.08.23 and 9903.08.24. CBP also bars 9903.08.26 until further guidance. Do not infer a filing calculation from the proclamation alone.
Did Revision 18 raise the beef tariff rate?
No. It implements a temporary 300,000-metric-ton increase in quota volume through heading 9903.54.02. The applicable quota and over-quota rates remain governed by the HTS; the announcement did not itself change those rates.
Does OFAC GL 55A permit a new Venezuela project to begin operations?
No. It authorizes due diligence and contingent-contract activity within its terms. Performance under the contemplated investment still requires separate OFAC authorization.
Has USITC banned Samsung mobile devices?
No. The Commission is reviewing parts of an initial determination and considering remedy issues. No final exclusion order or cease-and-desist order has been issued in the cited notice.
Sources and publication dates
- USITC, 2026 HTS Revision 18 and modification sources — published September 2, 2026.
- CBP CSMS #69738151, UAS Section 232 guidance — issued September 2, 2026.
- Proclamation 11055 and annex, 91 FR 53699 — published August 19, 2026; relevant duties effective September 3.
- OFAC General Licenses 51D, 54C and 55A — issued September 2, 2026.
- Commerce, Austrian OCTG preliminary CVD determination — published September 3, 2026.
- Commerce, Mexican heavy-walled rectangular pipe final AD review results — published September 3, 2026.
- USITC, Certain Mobile Electronic Devices, Inv. 337-TA-1432 — published September 3, 2026.
Disclaimer: This publication is for general information only and is not legal, customs, sanctions or tax advice. Product scope, origin, valuation, entry date, company-specific rates and license conditions can change the result; review the controlling legal text and obtain professional advice for specific transactions.
