TRADE ALERT – STEEL, ALUMINUM AND COPPER IMPORTS
HEADLINE	Executive Order Adjusting 232 Duties on Certain Steel, Aluminum and Copper Products
DATE	June 16, 2026
AGENCY	Trump Administration; Department of Commerce; U.S. Trade Representative; U.S. Customs and Border Protection
EFFECTIVE DATE	June 8, 2026 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 revisions to the derivative lists. 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.     On April 2, 2026, the Section 232 order imposing tariffs on steel and steel products was significantly modified. The modification removed some items from the steel tariffs, added additional items, modified the tariff to be 50% on the total value of certain products and 25% on certain derivative products, and implemented reduced tariffs pursuant to certain trade agreements.
DETAILS	The new proclamation adjusts steel, aluminum, and copper tariffs for certain products and countries:   • Temporarily reduces agricultural equipment, like combines and harvesters, and certain HVAC systems and components to 15% through December 31, 2027, as listed in Annex III. • Applies a 15% reduced rate for articles classified in Chapters 84, 85, or 87 that will be used exclusively in the manufacturing of “agricultural equipment or fixed industrial equipment.” • Adds steel racks and aluminum lithographic plates. • Reduces the threshold for imported products considered to be made “entirely” from American aluminum, steel, or copper from 95% to 85%. • Applies a 15% rate (as opposed to 25%) for products in Annex I-C of Argentina, Ecuador, El Salvador, Guatemala, Japan, South Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or the EU, where the sum of the ordinary duty rate and the additional 232 tariffs shall be 15%. • Applies a 10% rate for derivative articles where the aluminum content was entirely smelted and cast in the U.S. or steel content was entirely melted and poured in the U.S. • Applies a 25% rate applicable to the non-U.S. content of products that qualify for preferential treatment under USMCA.  Ultimately, the application of metal 232 tariffs requires a fact-intensive examination of the product’s ordinary HTS classification, country of origin, origin of melt/cast, and use. We recommend a review of CBP’s CSMS detailing changes to the HTS and use of the current Chapter 99 notes when making 232 determinations.
BASIS	Section 232 of the of the Trade Expansion Act of 1962; 3 U.S.C. 301; 19 U.S.C. 2483
CITE	White House – Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper into the United States – The White House   Federal Register – Federal Register :: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States   Annexes: Annex I-A Annex I-B Annex I-C Annex II Annex III Annex IV   CBP CSMS: CSMS # 68855869 – GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States

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