On April 2, 2026, a presidential proclamation revising the Section 232 tariff treatment of certain aluminum, steel, and copper articles and derivative articles was issued, effective 12:01 a.m. EDT on April 6, 2026. We are writing to advise you of the details of these important changes.
Key Updates
- The additional duty applies to the full product value, not just the metal content.
- Multi-metal goods are subject to the applicable 232 duty only once, not cumulatively.
- For products outside of Chapters 72, 73, 74, and 76, the additional tariff only applies where the applicable metal content represents at least 15% of the total weight of the product. If an HTS provision appears on multiple lists, the listed metals are aggregated for this test.
- For qualifying UK goods, at least 95% of the aluminum must be smelted or most recently cast in the UK, or at least 95% of the steel must be melted and poured in the UK.
- For qualifying derivative articles, at least 95% of the aluminum, steel, or copper content must meet the required U.S. smelt/cast or melt/pour standard, and those requirements are cumulative where an article falls in more than one subdivision.
- Metal containers may be included in scope, even if they are filled with items not subject to steel, aluminum or copper tariffs.
- CBP will implement copper smelt and cast reporting requirements as soon as practicable.
Applicable aluminum, steel, and copper articles and derivative articles are categorized into various Annexes, each having their own base rate of duty and exceptions to that rate. The additional duties imposed under this proclamation are applied in addition to any other applicable duties, including anti-dumping and countervailing duties. Goods eligible for free trade agreement or preference program treatment still incur these Section 232 duties in addition to any otherwise applicable special rate. Chapter 98 remains available, but duties under 9802.00.60 are assessed on the full value of the imported article.
Annex I-A: 50% additional duty rate.
- Exception: 25% for qualifying UK aluminum and steel products.
- Exception: 10% for qualifying U.S. aluminum, steel, and copper derivative products.
Annex I-B: 25% additional duty rate.
- Exception: 15% for qualifying UK aluminum and steel products.
- Exception: 10% for qualifying U.S. aluminum, steel, and copper derivative products.
Annex II: No longer subject to the additional duty rate.
Annex III: Temporary framework which applies April 6, 2026, through December 31, 2027
- For Column 1 duty rates below 15%, the Column 1 duty rate combined with the Section 232 rate will total 15%.
- For Column 1 duty rates greater than or equal to 15%, the Section 232 rate is zero.
- Exception: 10% combined Column 1 and 232 duty rate for qualifying U.S. aluminum, steel, and copper derivative products
- Exception: 25% rate for products from trading partners the U.S. does not maintain normal trading relations with.
200% Russia Rate
Aluminum articles and derivative aluminum articles specified in Annexes I-A, I-B, and III that are a Product of Russia or where any amount of primary aluminum used in the manufacture is smelt in Russia, or these aluminum articles are cast in Russia, continue to be subject to the 200% rate of duty.
Foreign Trade Zones
Covered goods admitted to an FTZ on or after the effective date generally must enter under privileged foreign status.
Drawback
Drawback is limited to certain qualifying manufacturing drawback claims meeting specific conditions.
Impact on Customs Bonds
The implementation of any new tariff has the potential to push importers’ duty outlay beyond the value of their current customs surety bond. It is important to understand the impact of these tariffs to your customs surety and be proactive in addressing any surety shortfall. For more information, please click here.