TRADE ALERT – IMPORTS
HEADLINE	New Proclamation Makes Major Revisions to Section 232 Tariffs on Steel, Aluminum, Copper
DATE	April 2, 2026
AGENCY	Trump Administration; Department of Commerce; U.S. Trade Representative; U.S. Customs and Border Protection
EFFECTIVE DATE	April 6, 2026 at 12:01 a.m. Eastern time
BACKGROUND	On February 10, 2025, the Trump Administration issued the Aluminum Presidential Proclamation adjusting imports of aluminum into the United States (Proclamation 10895) (90 FR 9807) and the Steel Presidential Proclamation adjusting imports of steel into the United States (Proclamation 10896) (90 FR 9817), placing 25% duties on specified items, effective March 12, 2025.   On June 3, 2025, the tariff rate for steel and aluminum articles and their derivative items was increased to 50%. That Executive Order provided that the Section 232 tariffs applied only to the steel content of the article. The interpretation of this provision with respect to items classified in Chapter 73 of the HTSUS is the subject of a dispute at the Court of International Trade, Express Fasteners, Ltd v. United States, Case No. 26-853. Among other actions, the initial Proclamations directed and authorized the Department of Commerce to publish modifications to the HTSUS in the Federal Register, and required the establishment of a process for including additional derivative aluminum and steel articles within the scope of the ad valorem duties. As a result several additional lists of derivative products were added in 2025, most notably with the addition of 407 new HTSUS on August 15, 2025.
DETAILS	The new proclamation significantly modifies the existing Section 232 actions on steel and steel derivatives (Proclamation 9705), aluminum and aluminum derivates (Proclamation 9704), and copper and copper derivatives (Proclamation 10962), including the following major changes: Full value. Duties will now apply to the “full customs value” of the imported product, regardless of metal content. No Section 232 metal duty stacking. Duties will not “stack” for derivative products classified in multiple Section 232 metals actions. In other words, goods specified in Annex I-A, Annex I-B, and Annex III that are listed as articles or derivatives of more than one metal will only be subject to one application of the Section 232 metal duties. For products listed in Annex I-A (comprising all aluminum and steel articles, most copper articles, and certain derivative articles of aluminum and steel): • 50% duties will apply to the entire value of the imported item UNLESS the products are of United Kingdom origin and smelt/cast/melt/pour (25%) or United States smelt/cast/melt/pour (10%). For products listed in Annex I-B (certain copper articles and aluminum and steel derivative articles): • 25% duties will apply to the entire value of the imported item UNLESS the products are of United Kingdom origin and smelt/cast/melt/pour (15%) or United States smelt/cast/melt/pour (10%). For products listed in Annex II: • These articles will no longer be subject to Section 232 duties. For products listed in Annex III (certain industrial and electrical equipment), until December 31, 2027: • the applicable additional ad valorem rate of duty of the combined Column 1 and Section 232 duty rates will be 15% if the Column 1 rate is lower than 15%, or equal to the Column 1 rate if it is above 15% (this is similar to how the Reciprocal Tariffs operated for many countries that had “trade deals” before the IEEPA tariffs were struck down). • 10% duties (rather than 15%) will apply in the same manner outlined above for derivative articles containing aluminum and steel which was smelted/cast/melted/poured in the United States. New de minimis exemption. Products made of 15% or less steel, aluminum, or copper (determined by weight) will no longer incur Section 232 duties. If an article is comprised of multiple metals that are on multiple lists, however, the aggregate weight of the relevant metals is used to calculate the de minimis percentage. See Annex IV. The processes to include additional derivate articles are terminated, but new HTS codes may be added to the 232 duties on a case-by-case basis.   Drawback. Manufacturing drawback claims made in accordance with subsections (a) and (b) of section 313 of the Tariff Act of 1930, as amended, 19 U.S.C. 1313(a)–(b) is available so long as the product is classified in a listed HTSUS provision, is not subject to an AD/CVD order, and is a product of a Trade Agreement Partner (United Kingdom, the European Union, Japan, the Republic of Korea, Mexico, Canada, etc.) and contains metal that was smelted/cast/melted/poured in such territory.   New information requirements. CBP will implement further information requirements to establish what documents are necessary at entry to establish country of smelt/cast/melt/pour.
BASIS	Section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. 1862 (Section 232)
CITE	White House: STRENGTHENING ACTIONS TAKEN TO ADJUST IMPORTS OF ALUMINUM, STEEL, AND COPPER INTO THE UNITED STATES   Annexes: Metals-ANNEXES-I-A-I-B-II-III-IV.pdf

Recent Trade and Compliance Actions Homepage