Last week, the President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.” That proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective today (April 6, 2026). 

It is important to examine the tariff code for your goods, and compare it to the code listing for the tariff.  NOT ALL PARTS ARE SUBJECT TO THESE DUTIES!  Most bar stock and other non-finished products are covered.  Many wires and fasteners/hardware are covered. 

Many finished aircraft parts made from these materials are not covered; but some aircraft parts may be covered (like certain hydraulic fluid pumps under heading 8413, certain heat exchange units under 8419, and certain bearings under heading 8482 or 8483).  To be certain, it is important to check the annexes, which will be incorporated into the HTSUS.

Once you have identified your imports as being subject to one of these tariffs, then you still need to identify which of the annexes applies (based on tariff number) as well as the source of the material.  The actual calculation mechanism has gotten more complicated and is more fully described in the proclamation and annexes.  For more information, or if you need more guidance, then contact the Association.

Even if the tariff code for your import good is listed, you still need to check the metal content (by weight) because an additional exception may apply.  Goods specified in the annexes to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76, that contain less than 15 percent of the aggregate weight of the applicable metal(s) are not subject to the duties imposed by the Proclamation.  This is the sum of the applicable metals where there is more than one tariffed metal.  For example, since HTSUS is 8302.10.60 is identified in paragraphs (c)(vi) and (vii) of annex IV as both a derivative aluminum article and steel article in annex IV, the aggregate weight of both aluminum and steel (but not copper) should be included in the 15 percent calculation.  If you are able to use the “less than 15% weight” exception, then report it as HTSUS 9903.82.03, and include the aggregate weight of the applicable metal(s) in kilograms as a second quantity on the entry summary line.

The EASA alert includes detailed information on affected serial numbers, part numbers, engine types, and parts descriptions.

ASA members received an email notice about this on Friday, but we wanted to follow-up for community members who might not have received this notice.

To help you respond appropriately, ASA recommends reviewing the following possible actions:

1. Communicate the Information Internally and Externally

Ensure relevant team members—such as quality, supply chain, procurement, operations, and IT—are aware of this notice. Consider handling this as a company-wide notification for reinforcement of our shared responsibility for maintaining a safe supply chain. If applicable, consider sharing the information with trusted external partners who may be affected or may participate in related transactions.

2. Implement an Internal “Flag” for Identified Part Numbers

ASA encourages you to update your internal systems so that any transaction involving the listed part numbers triggers an alert. This flag is not intended to prohibit procurement; rather, it is intended to alert the company’s compliance professionals that additional verification steps may be necessary before the transaction proceeds.

3. Confirm Your Company Is Subscribed to Government Safety Notifications

While ASA will continue to share relevant alerts promptly, it is important that your organization is registered directly with the appropriate government agencies for official notices. Doing so helps ensure you receive real-time information on potential safety or compliance risks. You can create an EASA account and register for EASA unapproved parts notices on the EASA website. You can subscribe to FA unapproved parts notices and other FAA notices on the FAA’s website.

EASA Notification and Details

Full details about the stolen engine parts notice, including the list of affected components (with serial numbers), can be found here:
https://www.easa.europa.eu/en/domains/aircraft-products/suspected-unapproved-parts/theft-turbofan-engine-parts-mutilation

While this notice provides details regarding the stolen parts, ASA feels that even if your company is not involved in the engine parts market, you should think about how you would manage a notice that impacts your business line.

The Aviation Suppliers Association has posted comments on this draft document.

One comment that may be particularly important to members was a comment recommending additional text to better support disassembly of aircraft in Europe, and issue of EASA Form 1 for the parts that are removed from such aircraft.

Another ASA comment seeks to describe the state of being in “as removed” condition and to identify such parts as remaining in need of an airworthiness determination before use/installation.

There are reports that today, CBP amended its order, to remove the “immediacy” from the requirement to issue refunds. But the refunds still have to be issued. CBP is creating the CAPE system within ACE and has suggested that it could be ready within 45 days of the CIT order (so, mid-to-late-April).

In order to make use of the CAPE system – indeed in order to receive any refund – you will need an ACE account. This is because CBP recently changed the rules to require all refunds to be processed through the ACE system. Some importers rely on their customs broker or their carrier to process all of the imports, and may not yet have an ACE account. If that is your situation, then now is the time to obtain an ACE account.

The expected tariff refund process will be something like this:

1. File a declaration that itemizes the entries on which you’ve paid IEEPA-based duties; this will be filed within the ACE system (probably within the CAPE subsystem)
2. The ACE system validates the application against its own data and recalculates the duty owed without the IEEPA tariffs (to verify the refund amount)
3. CBP verifies the declaration and processes the refunds
4. CBP liquidates or reliquidates each validated entry
5. The ACE system should allow CBP to certify that the refund is owed and then the refund will be released by the Treasury
6. The refund will be deposited in the bank account that you registered for electronic refunds, through your ACE account

U.S. CBP has published a number of resources to assist in obtaining ACE accounts and setting them up to process refunds.

The are multiple cases described that involve aircraft parts. Here is a summary of few of them:

• Stefan Gillier was sentenced to 84 months in prison, three years of probation, $3,509,916 in restitution and an $800 special assessment after he was found in connection with a scheme to fraudulently obtain aircraft parts from Honeywell and export them through Turkey to Iran.
• Joyce Eliabachus was sentenced to 18 months in prison, one year of supervised release, and a $100 special assessment. She pled guilty to allegations that she conspired smuggle over $2 million worth of aircraft components from her NJ company to Iran, through intermediaries in the UAE and Turkey.
• David Levick was sentenced in the U.S. District Court for the District of Columbia to 24 months in prison, 12 months of supervised release, a $199,227 forfeiture, a $400 special assessment, and deportation upon completion of his sentence. He pled guilty to a scheme in which he would order aircraft parts from the United States to his business in Australia and ship them to the Malaysian facilities of an Iranian buyer, from where they would make their way to Iran.
• Erdal Akova was sentenced to 36 months in prison and a $200 special assessment for a scheme involving the shipment of military-grade epoxy (through his facility in Turkey) for use on aircraft in Iran.
• First Call International agreed to a civil penalty of $439,992 for shipments using the STA license exception when it was not applicable. The exports included shipments of defense aircraft through Australia (to make it seem like STA applied) when the ultimate consignee was actually in Malaysia.
• Brothers Issam and Usama Hamade were sentenced to 26 months and 42 months respectively, as well as $100 special assessments, post-incarceration deportation, and ten-year post-conviction denial orders. They were convicted of exporting inertial measurement units, digital compasses, a high-performance jet engine, and various other aircraft parts and avionics. They falsely claimed the goods were destined for South Africa when they were actually being shipped to Hezbollah in Lebanon.
• William Vanmanen was sentenced to 30 months in prison and 24 months of supervised release for a scheme involving false documentation, false designation of value, and exporting aircraft parts to Hong Kong without the required licenses.
• Ali, Marjan and Arash Caby were sentenced two years, one year and one day, and two years in prison, respectively. Other elements of the sentences included supervised release, criminal fines and forfeiture. The three plead guilty to selling aircraft parts to Syrian Arab Airlines.
• Muhammad Mohsin Raja was sentenced to 24 months in prison and one year of supervised release after he was found guilty of transmitting payments in connection with the purchase of aircraft antenna for a denied entity in Pakistan.

The U.S. International Trade Commission (USITC) has opened a new factfinding investigation.  The investigation is examining the impact of revoking normal trade relations treatment for China. This would dramatically increase the tariffs paid by U.S. importers who are importing Chinese-origin goods. For the ASA Community, this could affect aircraft parts but it could also affect raw materials imported and used to produce aircraft parts in the United States.

Removing Normal Trade Relations (NTR)

“Normal trade relations” is the term of art that describes the trade relationship between the United States and its trading partners. This is also called “most-favored nation” status in the World Trade Organization (WTO) context.

There are currently four countries that do not have normal trade relations with the United States: Belarus, Cuba, North Korea and Russia.  Those four countries pay much higher base tariffs.  Currently, the United States imports relatively little from these four jurisdictions.   For example, in 2025 the U.S. imported $3.8 billion in goods from Russia, and in 2024 the U.S. imported $3.0 billion in goods from Russia.

Compare this to imports from China: In 2024 the United States imported $438.7 billion in goods from China.  That volume slipped to just $308.4 billion in 2025 due to US-China trade disputes, but that is still a very large volume of imports.  The slippage from 2024 to 2025 shows that duty rates can have significant impact on import volumes.

The People’s Republic of China was granted normal trade relations status in February 1980, pursuant to title IV of the Trade Act of 1974 (19 U.S.C. 2431 et seq.).  In 2001, Public Law 106–286 (114 Stat. 880) was passed to make permanent the People’s Republic of China’s normal trade relations status.

The normal trade relations status made merchandise from the People’s Republic of China eligible for the duties set forth in column 1 of the HTSUS.  Column 2 is the column reserved for the four countries that do not enjoy normal trade relations with the United States.  For each tariff code, the column 2 duties are typically much higher.

The Effect of Removing NTR

If the United States revokes normal trade relations from China, then imports originating from China would be subject to the “column 2” duties.  China would become the fifth country added to the column list.

Column two of the HTSUS has higher duty rates, but what does that really mean?  Aircraft parts under HTSUS heading 8807 typically enjoy a zero percent base rate, but under column two they would be subject to a 27.5% duty rate.  Steel cotter pins are typically subject to a 3.8% duty rate but under column two they are subject to a 45% duty rate.  Aircraft jet engine parts are often admitted under a zero percent base rate, but under column two they would be subject to a 35% duty rate.  As you can see, moving China to column two dramatically increases the import duties that U.S. importers will pay.

Why Is This Happening?

In September, the House Appropriations Committee published a report that asked the USITC to investigate removing normal trade relations status from China.

Trade Enforcement Analysis.–The Committee directs the ITC to complete, no later than 180 days after the enactment of this Act, an investigation and prospective economic analysis of revoking permanent normal trade relations (PNTR) treatment of all products of the PRC on the U.S. economy, U.S. industry, and product sourcing over a six-year period. The ITC is further directed to provide this report to the Committee within 30 days of completion. The report should include the results of the ITC’s investigation and analysis including detailed information, to the extent practicable, on U.S. trade, production, and prices in the industries that would be directly and most affected by the imposition of rates of duty in Column 2 of the Harmonized Tariff Schedule (19 U.S.C. 1202) on products from China. The report should also examine an alternative scenario where Congress revokes PNTR with a five-year phase-in of tariffs on a subset of national security products.

There is also a strong likelihood that this investigation is being pursued to strengthen the Administration’s bargaining position in negotiations with China. We want to provide data to the US government and protect the traditional aviation carve-outs without weakening either side’s bargaining position.

We Need Your Help

Here’s where you come in.  As an industry, we need to compile data to show what the effect of this sort of change would be on American businesses.  We know that some of our members are sourcing Chinese origin materials as raw materials or subcomponents to their aircraft parts.  It is important that we let the government know how this will affect our industry, so they can make an informed decision.

History also shows us that when the United States imposes sanctions that affect another country, like China, the other country may impose sanctions on goods from the United States.  This means that a trade war can adversely affect aircraft parts both on the supply side and on the international sales side.

Please let ASA know:

• What volume of Chinese origin supply/materials are you sourcing?
• What is the annual dollar value of Chinese origin supply/materials that are you sourcing?
• What sorts materials are you sourcing from China?

We will need to file our responses with the government by 5:15 p.m. Eastern Time, on Monday, April 13, 2026, so we ask that members of ASA submit their data to ASA by Wednesday, April 1, 2026 so we can assemble it into an industry report.

The Court of International Trade issued their own tariff order today.

The judge determined he has exclusive jurisdiction to hear the matter, and directs CBP to:

• liquidate all unliquidated entries entered subject to IEEPA duties without regard to IEEPA duties;
• reliquidate, without regard to IEEPA duties, entries already liquidated for which liquidation is not final.

This means that if your import was not yet liquidated, then when it is liquidated, it will be charged without regard to the IEEPA tariff and if that money was collected then it should be refunded. It is possible that CBP may require some action on the part of the importer in order to execute this process (although they should not) so watch carefully for more updates.

The ruling also directs that if your import was not yet liquidated, then when it is liquidated, it will be charged without regard to the IEEPA tariff and if that money was collected then it should be refunded.

Of course, this could be subject to additional appeals so don’t consider anything final until you get your refund!

The White House issued an executive order calling for the establishment of new tariffs under Section 122 of the Trade Act of 1974 (19 U.S.C. 2132). The order demands that the government establish new tariffs setting a 10% duty rate on all foreign goods imported into the United States, starting tomorrow (February 24, 2026). The HTSUS code associated with this new tariff is expected to be 9903.03.01.

There is good news for industry: many aviation parts will be exempt from this new tariff. The exemption will apply to a list of HTSUS tariff codes that are typically associated with aircraft, engines, and their parts. The list is nearly 600 codes long, so it encompasses a significant number of aircraft parts classifications. Always check your HTSUS codes against this list for each import, to assess whether the additional duty applies to your import. The tariff provision that exempts aircraft parts from the new section 122 duty rate is expected to be 9903.03.05.

Section 122 permits the President to use tariffs to deal with large and serious United States balance-of-payments deficits. The United States has the world’s largest negative balance of payments; however, this provision only permits tariffs of up to 15% for up to 150 days. After that the tariffs can only be extended by an act of Congress.

Please note: this blog article is based on the Administration’s executive order. Tariff rules can be (and have been) changed between the executive order that announces them and the formal publication in the Federal Register. So please don’t make any legal moves until you have reviewed the final published language.

UPDATE: the 10% tariff has been established as predicted, and when into effect this morning (Feb 24, 2026).

It is possible that the administration may create a streamlined mechanism for seeking/issuing tariff refunds. This article describes processes under current law and regulations. We have reached out to the government to seek advice on streamlined filing for refunds, and to offer assistance in streamlining the refund process.

The first step is to assess which tariffs you paid, and which of those were illegal. Not all tariffs were ruled to be illegal – only certain ones. For example, if you imported a bearing last July, and you paid a 9% duty for that bearing under HTSUS chapter 84 PLUS an additional 20% Chapter 99 tariff based on the fact that the bearing’s origin was from the European Union (total of 29% duty), then it is likely that the 9% duty from the base tariff was legal but the 20% duty could be covered under the Supreme Court’s recent ruling.

By and large, the illegal tariffs were issued under HTSUS Chapter 99 so if the basis of the duty that you paid was under another HTSUS chapter then it might have been a legal tariff. Also, some of the HTSUS Chapter 99 tariffs (like steel and aluminum) were issued under other justifications (not under the IEEPA) and those would remain unaffected by today’s ruling.

Once you’ve identified duties that you paid that might be covered by the Supreme Court’s ruling, the next step is to assess whether the import has been liquidated or not. The term Liquidation means the final computation or ascertainment of duties on thing sthat are entered into the United States for consumption. Liquidation usually happens between 300 and 360 days after the import entry (the government aims for an average of 314 days, but our recent assessment found that the average was 330-335 days).

If your import has not yet been liquidated, then you may be able to perform a post-summary correction. Typically this can be accomplished within 300 days of entry but also at least 15 days before liquidation. This is processed through the ACE system. If you discover an error, there is actually a legal obligation to file a correction.

If the 300-day window has passed or the entry has been liquidated, then you can no longer file a post summary correction. Instead, you may be able to file a protest. Protests typically are required to be filed within 180 days of liquidation.

Protests are filed using CBP Form 19. You can file this as a paper form (in which case it must be filed in quadruplicate, and sent to the Port Director) or you can file it online through ACE. If you file a paper copy then we usually advise that you send a fifth copy and a self-addressed stamped envelope in order to get a date-stamped copy back from CBP (as proof of receipt). The filing is considered filed when it is received (not when it is mailed) so make sure it gets to the destination on time!

When you file CBP Form 19, you need to be as specific as you can be. Make sure you provide this information:

• Identify what is wrong
• Explain why it is wrong
• Provide evidence
• Explain what the corrected entry should be

In the online/electronic form the space to provide this information is small, so don’t be afraid to write up your full argument on a separate document and attach it.

Please note that the following analysis is based on the regulations and standards as they are written today.  Export and import law, is subject to change.  This is particularly true of tariffs over the past year.  So you should always verify your classification under the current regulations and standards.

Classification is necessary for both exports and imports.  Exports of civil aircraft parts are typically classified under Export Commodity Classification Numbers or ECCNs.  An exception arises when the goods are controlled under the International Traffic in Arms Regulations (ITARs).

Export Classification

ECCNs are typically five characters long.  Many civil aircraft parts are characterized under ECCNs like 9A991, but this ONLY applies to civil aircraft parts that are (1) not specified elsewhere and (2) specially designed for civil aircraft.  The first condition is important because some parts (like engines, avionics, etc.) are specified elsewhere and may have different export limits and licensing provisions based on their proper classification.  

In our case, IRUs are typically classified elsewhere.  Even though they may be aircraft parts, when there is a more specific classification, they must rely on the most specific classification.

Many civil aircraft IRUs are classified under ECCN 7A103.  One might be tempted by ECCN 7A003, but the regulations specify that ECCN 7A003 “does not apply to ‘inertial measurement equipment or systems’ which are certified for use on ‘civil aircraft’ by civil aviation authorities of one or more Wassenaar Arrangement Participating States.”

ECCN 7A103 has two primary reasons for control: missile technology (MT) and anti-terrorism (AT). The missile technology reason for control could be an issue for many export destinations, as there is a license obligation associated with most export destinations (currently there are exceptions for Australia, Canada,and the UK). If you plan to rely on a license exception, then please read the regulations carefully as some destinations may be unable to rely on certain license exceptions when exporting articles controlled under ECCN 7A103.

Import Classification

Imported goods are typically classified under harmonized tariff codes from the Harmonized Tariff Schedule of the United States (HTSUS).  These codes can be ten digits long (when you include the statistical reporting number).  There are also a lot more tariff numbers than there are ECCNs, which makes navigating the tariff schedule a little more daunting.  

The United States Government has classified civil aircraft IRUs under HTSUS heading 9014.20.8040 for import purposes. Note that if you click through the link, you will see an outdated number that was assigned; 9014.20.8040 is the modern equivalent tariff number. But that assignment relies on a specific fact pattern: that the IRU (a) is not an optical instrument, (b) does not measure an electrical phenomenon, and (c) is for use in civil aircraft. Other types of inertial measuring device have fallen into other HTSUS classifications (like a Northrupp Grumman IMU that was characterized as 9014.20.20 in the year 2020). So look carefully at the characteristics of your device to ensure it is properly classified under 9014.20.8040.

Proper tariff classification is important because different tariffs have different duty amounts.  9014.20.8040 is specific to aviation use inertial reference units, so classification under 9014.20.8040 currently yields a base duty of zero percent (this may be modified by chapter 99 tariffs).

Past Classification Articles

• Fasteners