USTR has lifted the suspension of liquidation on U.S. imports from ThyssenKrupp’s San Luis Potosí facility under the USMCA RRM.

Regulatory Briefing: Resumption of Liquidation for Imports from ThyssenKrupp Springs & Stabilizers de México (San Luis Potosí)

1. What changed

• USTR has concluded the USMCA Rapid Response Labor Mechanism (RRM) matter involving ThyssenKrupp Springs & Stabilizers de México, S. de R.L. de C.V., located in San Luis Potosí, Mexico.
• Effective with Ambassador Greer’s March 16, 2026 letter, USTR is no longer directing the suspension of liquidation of unliquidated entries of goods from this specific facility.
• CBP and Treasury have been notified to resume liquidation of all unliquidated entries from the facility that were previously subject to suspension under section 752(a) of the USMCA Implementation Act (Pub. L. 116‑113).
• The action restores normal liquidation processing; it does not itself change duty rates or HTS classifications, but it directly affects timing and finality of duty assessment for affected imports.

2. Affected products

• Facility: ThyssenKrupp Springs & Stabilizers de México, S. de R.L. de C.V.
• Location: City and state of San Luis Potosí, Mexico.
• Products: Automotive suspension components, including springs and stabilizer bars used in motor vehicles.
• Likely HTSUS headings/subheadings (examples – importers must confirm their own classifications):
• 8708.80.xx: Suspension systems and parts thereof (including shock absorbers) for motor vehicles of headings 8701–8705.
• 7320.20.xx: Helical springs of iron or steel.
• 7320.90.xx: Other springs and leaves for springs, of iron or steel.
• 8708.80.65 / 8708.80.65xx: Parts for suspension systems (including stabilizer bars) for certain motor vehicles.
• Scope limitation: The action is facility-specific. It applies only to goods produced at the ThyssenKrupp Springs & Stabilizers de México facility in San Luis Potosí that were subject to the RRM-related suspension of liquidation. It does not apply to all ThyssenKrupp entities or all Mexican automotive parts generally.

3. Rate changes

• There is no change to the underlying MFN or preferential duty rates or to HTSUS classifications as a result of this action.
• The key change is procedural: suspension of liquidation has been lifted, and CBP may now liquidate previously unliquidated entries.
• During the suspension period, entries remained unliquidated; duties were deposited at the applicable rates in effect at time of entry (e.g., MFN or USMCA preferential rates, often 0% for qualifying automotive parts). Those rates remain unchanged; what changes is the ability of CBP to finalize (liquidate) the entries.
• No new additional duties (e.g., Section 232, 301, 201) are created or modified by this action.

4. Dates

• Petition received by Interagency Labor Committee (ILC): October 14, 2025.
• USTR direction to suspend liquidation under USMCA Implementation Act section 752(a): November 13, 2025.
• From this date, CBP was directed to suspend liquidation of all unliquidated entries of goods from the ThyssenKrupp San Luis Potosí facility.
• Mexico’s review and remediation: Conducted after November 13, 2025; concluded with measures deemed sufficient by USTR (no specific end date provided in the text, but remediation is acknowledged as complete by March 2026).
• USTR letter lifting suspension and resuming liquidation: March 16, 2026 (date on PDF letter).
• Effective date: The resumption of liquidation is effective upon USTR’s notification to Treasury (March 16, 2026). CBP will implement this operationally; importers should expect liquidation activity to resume thereafter.
• Duration of impact:
• Suspension period: November 13, 2025 through March 16, 2026 (or until CBP operationalizes the resumption).
• After March 16, 2026: CBP may liquidate all previously suspended unliquidated entries from the facility.

5. Required actions for importers, brokers, and compliance teams

5.1 Identify impacted entries

• Determine whether your company imported goods from the ThyssenKrupp Springs & Stabilizers de México facility in San Luis Potosí during or before the suspension period.
• Work with suppliers to confirm plant-of-production; do not assume all ThyssenKrupp shipments are in scope.
• Review commercial invoices, certificates of origin, and supplier declarations for plant identifiers (e.g., address in San Luis Potosí, Mexico).
• Pull a list of entries filed with CBP that:
• Contain automotive suspension components (e.g., HTSUS 8708.80.xx, 7320.xx, or other relevant parts codes), and
• Were entered on or before November 13, 2025 and remained unliquidated, or were entered after November 13, 2025 and were subject to the RRM-related suspension.
• Use ACE reports (e.g., ES-501, ES-502) or broker reports to identify entries with liquidation status “suspended” or “unliquidated” tied to this facility.

5.2 Prepare for liquidation and potential duty impacts

• Because liquidation will now resume, importers should:
• Verify that all classifications, declared values, and country-of-origin/USMCA claims for affected entries are correct.
• Confirm that any USMCA preferential duty claims are properly supported (valid certifications of origin, regional value content calculations, etc.).
• Assess whether any post-summary corrections (PSCs) or prior disclosures are needed before CBP liquidates the entries.
• Timing considerations:
• Once CBP liquidates an entry, the 180-day protest window under 19 U.S.C. § 1514 applies.
• Importers should monitor liquidation notices closely to ensure they do not miss protest deadlines if they disagree with CBP’s final duty assessment.

5.3 Coordinate with brokers

• Instruct customs brokers to:
• Flag all entries from the ThyssenKrupp San Luis Potosí facility that have been in suspended status.
• Notify your company promptly when CBP begins liquidating these entries.
• Provide detailed entry data (HTS, value, duty paid, USMCA claim status) for internal review before and after liquidation.

5.4 Internal compliance and documentation

• Maintain documentation demonstrating:
• The facility of production (ThyssenKrupp Springs & Stabilizers de México, San Luis Potosí).
• The basis for any preferential duty claims (USMCA certificates, supplier statements).
• Any internal reviews or corrections made in anticipation of liquidation.
• For companies with ESG or labor-compliance commitments:
• Note that the RRM matter has been resolved with remediation measures, including reinstatement of workers, neutrality commitments, and training on freedom of association and collective bargaining.
• Update internal risk assessments to reflect that the facility is no longer under an active RRM suspension of liquidation.

5.5 No new filing or licensing requirements

• The USTR action does not impose new licensing, quota, or special entry-type requirements.
• Standard entry procedures continue to apply; the key change is that CBP is now authorized to liquidate previously suspended entries.

6. Context and risk considerations

• Legal basis: Section 752 of the USMCA Implementation Act (Pub. L. 116‑113):
• Section 752(a): Allowed USTR to direct suspension of liquidation of entries from a covered facility when there is sufficient evidence of a denial of labor rights under the USMCA RRM.
• Section 752(b): Provides for lifting that suspension once USTR determines that the denial of rights has been remedied.
• This case demonstrates that:
• Facility-specific labor-rights issues can directly affect the liquidation status of U.S. imports, even without changing duty rates.
• Future RRM petitions could similarly result in suspension of liquidation for other facilities in Mexico.
• Importers sourcing from Mexican facilities should:
• Monitor USTR and DOL announcements for new RRM petitions and determinations.
• Include labor-compliance and union-rights risk in supplier due diligence, as non-compliance can lead to customs impacts (e.g., suspension of liquidation, potential penalties in other cases).

7. References and source documents

• USTR Press Release: “United States Announces Successful Resolution of Rapid Response Labor Mechanism Matter at ThyssenKrupp Springs & Stabilizers de México, S. de R.L. de C.V.”
• Main points: Resolution of RRM matter; resumption of liquidation of tariffs on goods from the facility; description of remediation actions by the company and Government of Mexico.
• USTR Letter to Secretary of the Treasury (Ambassador Greer) – Resumption of Liquidation (March 16, 2026):
• PDF: https://ustr.gov/sites/default/files/files/Press/Releases/2026/ThyssenKrupp%20Resumption%20of%20Liquidation%20Letter%20-%203.16.2026.pdf
• Key language: Confirms that, after the November 13, 2025 direction to suspend liquidation under section 752(a), a condition in section 752(b) has been met and USTR is no longer directing suspension of liquidation of unliquidated entries from the facility.

8. Practical next steps checklist

• Immediately:
• Confirm whether your company imports from ThyssenKrupp Springs & Stabilizers de México, San Luis Potosí.
• Obtain a list of all unliquidated entries from this facility from November 13, 2025 onward.
• Within the next 30–60 days (or before CBP liquidates):
• Review classifications, values, and USMCA claims for all affected entries.
• File any necessary PSCs or prior disclosures.
• Set up monitoring for liquidation notices and protest deadlines.
• Ongoing:
• Track future USMCA RRM actions that may affect other suppliers.
• Integrate labor-rights compliance into supplier risk assessments to anticipate potential customs impacts.

This briefing should be used in conjunction with the official USTR documents and CBP guidance as they become available. Importers should consult with customs counsel for entry-specific legal advice, particularly regarding any contested liquidations or potential protests.