US import regulations and what to know when selling to the United States

1. US tariff snapshot (updated 13 October 2026)

For steel structures (HTS 7308) and other steel products: check the 8-digit HTS line in U.S. Note 16 to Chapter 99 and CBP CSMS #68253075 to see whether 50% or 25% applies; declare the country of melt and pour of the steel.

Still moving: Section 301 overcapacity investigation of 16 economies (including Vietnam) covering steel, aluminium, machinery…; litigation on Section 122 and de minimis. Re-check before quoting DDP prices.

2. Main agencies

• U.S. Customs and Border Protection (CBP) – clearance, duty collection, origin, marking, ISF, UFLPA enforcement (cbp.gov).
• U.S. International Trade Commission (USITC) – publishes the HTSUS (hts.usitc.gov); injury investigations in AD/CVD cases.
• Department of Commerce (ITA) – AD/CVD, Section 232, derivative product lists.
• USTR – Section 301, trade agreements.
• Partner agencies: FDA (food, medical devices), EPA (TSCA – chemicals, composite wood), CPSC (consumer product safety), FCC (electronics), USDA/APHIS (plants, wood packaging ISPM 15), DOT/NHTSA (vehicles).

3. The US import process

1. Importer of Record (IOR) with an identification number and a customs bond (continuous or single-entry).
2. ISF 10+2 (Importer Security Filing) for ocean cargo – filed at least 24 hours before loading abroad; penalties up to USD 5,000 per violation.
3. Entry (CBP Form 3461 or ACE) within 15 days of arrival; entry summary (CBP Form 7501) and duty payment within 10 working days of release.
4. Complete data: 10-digit HTS, transaction value (the US uses FOB, not CIF), origin, Section 232 data (country of melt/pour), applicable Chapter 99 numbers.
5. Liquidation – typically about 314 days after entry; protests within 180 days of liquidation.
6. De minimis (duty-free ≤ USD 800) has been suspended for all countries since 29 Aug 2025 and was reaffirmed in 2026.

4. Origin, marking and anti-circumvention

• Non-preferential origin follows substantial transformation; CBP rulings matter.
• Country-of-origin marking (19 U.S.C. 1304; 19 CFR Part 134): goods and containers must be marked "Made in Vietnam" in English, legibly and permanently.
• For steel: report the country of melt and pour – third-country steel processed in Vietnam remains subject to Section 232 and may face AD/CVD circumvention inquiries if Vietnamese processing is minor.
• Enforce and Protect Act (EAPA): CBP investigates AD/CVD evasion through transshipment; interim measures and back-duties can follow.
• UFLPA (Uyghur Forced Labor Prevention Act, 2022): goods with inputs or processing linked to Xinjiang are presumed made with forced labour and detained – exporters need supply-chain traceability (down to mines and smelters).

5. Public procurement: Buy American, BABA, TAA

• Build America, Buy America Act (BABA, 2021): federally funded infrastructure requires iron and steel produced in the US – all processes from initial melting; structures fabricated in Vietnam are generally not eligible for such projects (unless waived).
• Buy American Act (federal agency purchases) favours domestic goods; the Trade Agreements Act (TAA) only admits goods from "designated countries" in larger procurements – Vietnam is not designated.
• Private industrial and commercial projects are not covered – the main market for Vietnamese structural steel exports.

6. Technical requirements for structural steel in the US

• Design and fabrication to AISC 360 and AISC 303; welding to AWS D1.1 (qualified welders, WPS/PQR); materials to ASTM (A36, A572, A992, A500…), structural bolts to ASTM F3125.
• International Building Code (IBC): special inspection at the fabricator, unless the shop is AISC-certified or runs an accredited inspection programme (IAS AC472).
• Quality records: mill test reports showing melt location, NDT reports (UT/MT), dimensional reports, coatings (SSPC), galvanizing (ASTM A123).
• Timber dunnage and crates must meet ISPM 15 (USDA/APHIS).

7. Checklist for Vietnamese structural steel exporters

• Determine the 10-digit HTS and applicable Chapter 99 line (Section 232 at 50% or 25%).
• Collect melt & pour evidence for all plates and sections; consider steel melted where it is advantageous (e.g. US-melted steel at 10% under Section 232 from 6 Apr 2026).
• Agree Incoterms carefully: avoid DDP unless Section 232 on the full value is priced in; prefer FCA/FOB/CIF so the importer bears duties.
• Check AD/CVD orders and circumvention inquiries for the product and inputs.
• Keep UFLPA supply-chain traceability files.
• Mark components and packages "Made in Vietnam".
• Meet AISC/AWS/IBC; consider AISC certification or IAS AC472.
• Track changes: Section 301 overcapacity, Section 232 derivative lists, IEEPA refunds (if duties were paid).