On July 30, 2025, President Trump issued a proclamation imposing a tariff of 50% on all semi-finished copper and intensive copper derivatives, irrespective of origin, effective August 1, 2025 (including goods already in transit at the time the tariffs take effect).
Like the steel and aluminum tariffs, the tariff on copper is imposed under Section 232 of the Trade Expansion Act of 1962. There is no opportunity for duty drawback.
New requirements
The new tariffs on semi-finished copper and intensive copper derivatives apply only to the value of the copper content of the product. If the copper content value cannot be determined separately from the non-copper content, duties apply against the full value of the product. Duty for products entirely composed of copper is based on the total value of the copper product. The value of the copper content must be calculated using the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a, which bases the Customs value on the transaction value of the goods, which is the price actually paid or payable for the goods (19 CFR 152.103).
Documentation supporting valuation must be retained and presented to U.S. Customs and Border Protection (CBP) if requested. Examples of substantiating documentation include, but are not limited to, the bill of materials for the production of the goods, invoices for the materials used in the production of the goods, and accounting documentation.
Stacking and duties on non-copper content
While the 50% tariff rate is not applied to the non-copper content, the non-copper content is subject to tariffs pursuant to IEEPA Reciprocal, IEEPA Canada, IEEPA Mexico, and IEEPA China. In the event a product is subject to both the 232 Copper and 232 Auto and Auto Parts remedies, the product is subject to 232 Auto and Auto Parts and not 232 Copper.
Penalties for underreporting the value of copper
Importers who state values below the true value of the copper content of their product may be subject to disciplinary action, including severe monetary penalties, loss of import privileges and criminal liability.
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