Exporting Lighters, Plastic Furniture Fittings & Playing Cards

EU Retaliates on these items due to Section 232 Announcements

On January 24, 2020, President Trump issued a proclamation in regards to steel and aluminum imports pursuant to section 232 of the Trade Expansion Act of 1962. In retaliation to this announcement, the European Union has announced it will also target certain American-made products with additional tariffs.

EU Retaliates

Effected products imported from the United States into the European Union include:

  • Effective May 8, 2020
  • lighters @ 20% additional duty
  • plastic furniture fittings @ 7% additional duty

  • Effective whichever date comes first: (1) Feb. 8, 2023, or (2) when the World Trade Organization adopts a ruling that the U.S. measures are inconsistent with WTO rules
  • playing cards @ 4.4 percent additional duty in addition to the current ad valorem duty of 10% from previous retaliation orders


Effective February 8, 2020, an additional tariff was imposed for aluminum and steel derivatives.

  • an additional duty of 10% will be imposed on derivative aluminum articles
  • The aluminum derivative tariffs will apply to all countries except Argentina, Australia, Canada, and Mexico.
  • an additional duty of 25% will be imposed on derivative steel articles
  • The steel derivative tariffs will apply to all countries except Argentina, Australia, Brazil, Canada, Mexico and South Korea.

What Qualifies as an Aluminum or Steel “Derivative”

An article is “derivative” of an aluminum article or steel article if all of the following conditions are met:

  • the aluminium or steel article represents, on average, two-thirds or more of the total cost of materials of the derivative article
  • import volumes of such derivative article increased year-to-year since June 1, 2018 in comparison to import volumes of such derivative article during the 2 preceding years
  • import volumes of such derivative article following the imposition of the tariffs exceeded the 4% average increase in the total volume of goods imported into the United States during the same period since June 1, 2018.

Examples of such derivatives include:

The derivatives currently have a very narrow scope.  Such examples include specific steel nails, tacks, drawing pins, corrugated nails, staples, aluminum stranded wire, cables, plaited bands, bumper and body stampings of aluminum and steel for motor vehicles and tractors.  The Secretary of Commerce specifies the exact “derivative articles” of aluminum in Annex I and of steel in Annex II of the White House proclamation and in subchapter III of chapter 99 in the HTSUS.

What to do

There are a number of things you can do.  Scarbrough Consulting, Inc. is offering a free 30-minute consultation to any company that may be affected by Section 232 or 301 announcements.  Please send an email to consulting@scarbrough-intl.com or fill out the form below.  Our Global Trade Experts and Licensed Customs brokers are here to help, whether it’s duty drawback, product exclusions via post summary corrections or protests, or simply helping you to optimize your supply chain and add to your bottom line.  We have listed just a couple below, but there are other things to think about when it comes to your overall supply chain, and we are here to help.

About Scarbrough

The Scarbrough Group of Companies, headquartered in Kansas City with local presence in every major port in the world, is a complete international and domestic supply chain service provider, offering U.S., Mexican, and Canadian Customs brokerage, Import & Export Transportation Solutions, Domestic brokerage and asset-based trucking, Warehouse fulfillment and distribution services, Trade Compliance Consulting, Large Equipment and Project Cargo moves, as well as Parcel Audit Savings.  Scarbrough is widely known for its trade experts, training, personalized customer service, customized solutions, and data analytics tools.  Since 1984, Scarbrough has continued to satisfy its clients by following its motto on a daily basis: “It is our job to make your job easier.”  Moreover, our team of experts is available at your disposal.  We offer free consultations on any topic from supply chain optimization and duty savings opportunities to the basics, helping to guide new importers and exporters as they jump into the world of global trade.  Contact us now.