On September 11, 2018, the Department of Commerce published in the Federal Register an amendment to the rules on the submission and processing of exclusions requests on steel and aluminum articles subject to duties and quotas under Section 232 of the Trade Expansion Act. As noted below, rebuttal comments are now due as early as September 18. Duties of 25% ad valorem on steel and 10% ad valorem on aluminum have been in effect for certain countries since March 23, 2018.