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U.S. Adjusts Section 232 Tariffs on Aluminum, Steel, and Copper (New Proclamation Further Adjusting Tariff Regimes; CBP Guidance Available)


Published April 2, 2026 | Updated June 6, 2026

Key Points

  • April 6, 2026: Tariffs apply to the full customs value of all covered metal articles and derivatives, regardless of metal content.
  • 50% rate: Aluminum articles, steel articles, most copper articles, and certain derivatives listed in Annex I-A. Includes products made entirely or almost entirely of these metals, such as steel coils and aluminum sheet.
  • 25% rate: Certain copper articles and select aluminum/steel derivatives listed in Annex I-B. Applies to derivative articles substantially made of steel, aluminum, or copper.
  • 15% transitional rate: Metal-intensive industrial equipment and electrical grid equipment through December 31, 2027, to support the ongoing US industrial base buildout.
  • UK reduced rates: 25% (Annex I-A) and 15% (Annex I-B) for qualifying UK-origin metal content, pending ongoing trade discussions.
  • US-origin metal: 10% — Available for derivative articles made entirely with US-smelted/cast/poured aluminum, steel, or copper.
  • Russia 200%: Continues for all Russian-origin aluminum articles and derivatives under Proclamation 10522.
  • Low metal-content products removed: Products made of 15% or less steel, aluminum, or copper will no longer be subject to Section 232 metals tariffs.
  • Latest: On June 1, 2026, President Trump signed a new proclamation further adjusting the Section 232 tariff regimes on aluminum, steel, and copper. Changes take effect June 8, 2026 through December 31, 2027. CBP issued implementation guidance on June 5, 2026 (CSMS #68855869).

P​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​resident Trump signed a proclamation on April 2, 2026, significantly strengthening the existing Section 232 tariff regimes on aluminum, steel, and copper imports.

Taking effect at 12:01 a.m. ET on April 6, 2026, the action modifies tariffs originally established under Proclamation 9704 (aluminum), Proclamation 9705 (steel), and Proclamation 10962 (copper).

The proclamation redefines how tariffs are assessed, ensuring they reflect the full value of imported steel, aluminum, and copper products rather than an ‘artificially low foreign price’. This represents a significant shift from the prior methodology, under which tariffs on many derivative articles applied only to the declared metal content value within a product.

Latest Update: June 1, 2026 Proclamation

President Trump signed a new proclamation on June 1, 2026, further modifying the Section 232 tariff regimes established under Proclamation 11021, accompanied by a Fact Sheet. All changes take effect June 8, 2026 and are temporary through December 31, 2027, after which products revert to standard Proclamation 11021 rates.

Key Changes

  1. Annex I-C: New Temporary Rate Structure: Aluminum and steel articles listed in Annex I-C are subject to a new temporary rate structure through December 31, 2027. The standard rate is 25%, with lower rates available for trade deal country imports, USMCA-qualifying goods from Canada and Mexico, and products made with at least 85% U.S.-melted or smelted metal.
  2. Agricultural Equipment (25% → 15%): Certain types of agricultural machinery, such as combines and harvesters, now qualify for the 15% transitional rate, reduced from 25%. These were previously at 25% as standard steel/aluminum derivative articles.
  3. Residential HVAC (25% → 15%): Certain residential HVAC systems and components are now included in the expanded category of derivative products subject to the temporarily-reduced 15% ad valorem duty.
  4. Mobile industrial equipment (e.g., bulldozers, forklifts) are now eligible for the 15% rate, but only when imported from trade deal partner countries (EU members, UK, Japan, South Korea, Argentina, Ecuador, El Salvador, Guatemala, Liechtenstein, Switzerland, Taiwan, Canada, Mexico). Non-trade-deal-country imports of these products remain at 25%.
  5. U.S.-Origin Metal Threshold Lowered (95% → 85%): The threshold for products to qualify as “made entirely” from American metals has been lowered from 95% to 85%, intended to incentivize increased use of American aluminum, steel, and copper in downstream derivative products.
  6. New Products Added to Derivative Coverage: Aluminum lithographic plates and steel racks are now subject to the applicable derivative tariff under Proclamation 11021, having previously fallen outside Section 232 coverage.

CBP Implementation Guidance (June 5, 2026)

New Chapter 99 Headings: 9903.82.20–9903.82.26

CBP’s June 5 guidance provides filing instructions for new headings 9903.82.20–9903.82.26, applicable to goods entered on or after June 8, 2026 and before January 1, 2028.

New HTS classifications subject to Section 232 duties effective June 8, 2026

The following HTSUS classifications are newly subject to Section 232 duties under Proclamation 11021, as amended:

  • 3701.30.00
  • 9403.20.0075
  • 9403.20.0082
  • 9403.99.9040

HTS classifications subject to reduced Section 232 duty rates effective June 8, 2026

See the attached Metals HTS List for the Chapter 1–97 HTSUS classifications corresponding to each Chapter 99 heading. All changes are indicated in bold in the attachment.

U.S.-origin metal threshold lowered from 95% to 85%, effective June 8, 2026

Headings 9903.82.06, 9903.82.07, 9903.82.08, 9903.82.23, and 9903.82.24 apply to certain articles of copper and derivative aluminum and steel articles. Effective June 8, 2026, the threshold to qualify as made “entirely” from American metal is modified from 95% to 85%, as follows:

  • For derivative articles under subdivisions (c)(ii), (vi), and (ix): at least 85% of the aluminum content must be composed of aluminum smelted and cast in the United States.
  • For derivative articles under subdivisions (c)(iv), (vii), (x), and (xi): at least 85% of the steel content must be composed of steel melted and poured in the United States.
  • For articles under subdivision (c)(viii): at least 85% of the copper content must be composed of copper smelted and cast in the United States.
  • These requirements are cumulative: a derivative article falling under more than one subdivision must satisfy each applicable requirement.

New Chapter 99 headings: 9903.82.20–9903.82.26

These headings apply to goods entered on or after 12:01 a.m. ET on June 8, 2026, and before January 1, 2028.

9903.82.20 and 9903.82.21: USMCA-eligible derivative steel articles from Canada and Mexico

These headings apply to derivative steel articles from Canada and Mexico that are eligible for special tariff treatment under the USMCA, as provided in subdivision (c)(xi) of U.S. Note 16.

  • 9903.82.20 (25%): Applies to the non-U.S. content of such derivative steel articles, and to any U.S. content that exceeds 40% of the value of the article.
  • 9903.82.21 (0%): Applies to the U.S. content of such derivative steel articles, up to 40% of the total entered value. Do not report more than 40% of the value of U.S. content under this heading.

For purposes of U.S. Note 16, U.S. content refers to the value of the article attributable to parts produced in the United States. Non-U.S. content is calculated by subtracting the U.S. content value from the total value of the article. Special two-line entry reporting is required; see reporting instructions below.

9903.82.22: Derivative steel articles from specified countries (15%)

Applies to derivative steel articles, as provided in subdivision (c)(xi) of U.S. Note 16, that are the product of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union.

  • 15% additional ad valorem rate of duty.

9903.82.23–9903.82.26: Parts for use in manufacturing agricultural or industrial equipment

These headings apply to parts classifiable in Chapters 84, 85, or 87 under subdivision (c)(vi)–(viii) that will be used exclusively in the manufacturing of agricultural equipment or fixed industrial equipment under subdivision (c)(ix)–(x), or mobile industrial equipment under subdivision (c)(xi). These headings do not apply to products of Belarus, Cuba, North Korea, or Russia.

  • 9903.82.23: Column 1 rate less than 10% — the sum of the column 1 rate and the Section 232 additional duty will equal 10%.
  • 9903.82.24: Column 1 rate 10% or higher — no additional duty is due.
  • 9903.82.25: Column 1 rate less than 15%; the combined rate will equal 15%.
  • 9903.82.26: Column 1 rate 15% or higher; no additional duty is due.

Note: Filing instructions for headings 9903.82.18 and 9903.82.19 will be provided by CBP at a later date.

Transitional rates: January 1, 2028 changes

Headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 apply only to goods entered before January 1, 2028. From that date, those goods will be subject to the rates under 9903.82.05, 9903.82.06, and 9903.82.09.

Headings 9903.82.20–9903.82.26 also apply only through December 31, 2027. Effective January 1, 2028, goods currently covered by those headings will be subject to the rates under 9903.82.05, 9903.82.06, 9903.82.09, 9903.82.15, and 9903.82.16.

CBP will issue additional guidance before January 1, 2028.

Reporting instructions for HTSUS 9903.82.20 and 9903.82.21

When claiming treatment under 9903.82.20 and 9903.82.21, the non-U.S. content and U.S. content value of the derivative products must be reported on two separate lines.

First line: non-U.S. content:

  • Report the total quantity of the imported goods
  • Report the value of the non-U.S. content (total entered value minus the U.S. content value reported under 9903.82.21)
  • Report Section 232 duties on that value under 9903.82.20
  • Report Special Program Indicator (SPI) code “S”
  • Report the Chapter 1–97 HTSUS classification — the same must appear on both lines
  • Report country of origin (Canada or Mexico) — the same must appear on both lines
  • Report all other applicable duties, such as antidumping and countervailing duties

Second line: U.S. content:

  • Report 0 for quantity
  • Report the U.S. content value, up to 40% of the total entered value (do not report more than 40%)
  • Report 0% duty on that value under 9903.82.21
  • Report SPI code “S”
  • Report the same Chapter 1–97 HTSUS classification as the first line
  • Report the same country of origin as the first line
  • Report all other applicable duties, such as antidumping and countervailing duties

Russia aluminum duties

All imports of aluminum articles and aluminum derivative articles that are the product of Russia, or where any amount of primary aluminum used in their manufacture was smelted or cast in Russia, remain subject to the 200% ad valorem rate under HTSUS 9903.85.67 (aluminum products) and 9903.85.68 (aluminum derivative products). These products may not be reported under 9903.82.03.

Reporting of Countries of Melt and Pour and Smelt and Cast

Continue to report countries of melt and pour for all subject steel and steel derivative products, and countries of smelt and cast for all subject aluminum and aluminum derivative products. CBP will issue a separate CSMS message when reporting of copper smelt and cast countries is required and the corresponding functionality is available in ACE.

Background Info

The White House fact sheet issued on April 2, 2026 sets out five clear categories that determine which rate applies to a given product. The classification depends primarily on what proportion of the product is metal and whether that metal was produced in the United States.

50% – Entirely or almost entirely metal
Products that are made entirely or almost entirely of aluminum, steel, or copper pay a flat 50% on their full customs value. e.g. steel coils, aluminum sheet, copper rod.

25% – Substantially made of metal
Derivative articles substantially made of steel, aluminum, or copper pay a flat 25% on their full customs value. e.g. metal pipe fittings, structural components.

15% – Metal-intensive equipment (transitional)

Certain metal-intensive industrial equipment and electrical grid equipment pay 15% through December 31, 2027, to support the US industrial base buildout currently underway. e.g. transformers, switchgear, heavy machinery.

<15% – Low metal content (exempt)
Products made of <15% of steel, aluminum, or copper will no longer be subject to Section 232 metals tariffs.
Previously covered derivative articles with minimal metal content.

10% – Made with American metal
Products made abroad but entirely with US-smelted, cast, or poured aluminum, steel, and copper are subject to a reduced 10% rate. Documentation required to claim this rate at CBP.

Full Rate Structure

The applicable HTSUS Chapter 99 headings are 9903.82.02–9903.82.17. Classification depends primarily on metal content share, country of origin, and whether the metal was produced in the United States. Please refer to the full CBP Guidance – CSMS # 68253075 and access all Annexes.

Goods containing more than one covered metal are only subject to the applicable duty rate once — not stacked per metal. The highest applicable rate governs.

Technical Corrections to Section 232 Duties

CBP’s latest guidance provides instructions for importers, brokers, and filers on submitting entries subject to Section 232 duties on aluminum, steel, and copper imports.

The following changes apply retroactively to goods entered for consumption or withdrawn from warehouse for consumption on or after April 6, 2026 (12:01 a.m. ET).

  1. New HTSUS Subheading

The CBP guidance indicates:

“9903.82.01: Articles provided for in subdivision (c) of U.S. note 16 to this subchapter that do not contain any aluminum, steel, or copper.”

  1. UK-Origin Steel with Netherlands Melt and Pour
  • Applies to steel articles made by Tata Steel UK
  • Where reported country of melt and pour is the Netherlands
  • May continue under the lower Section 232 UK steel tariff rate
  • May be declared under HTS 9903.82.04
  • Valid through January 1, 2028
  • May count toward the 95% steel melted and poured threshold under HTSUS Note 16(d) for HTS 9903.82.04 and 9903.82.05

The attached Metals HTS List provides the full set of applicable tariff classifications for aluminum, steel, copper articles, and derivatives.

For questions regarding Section 232 entry filing, contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.

Previous Updates

The April 27 notice modifies Chapter 99 of the HTSUS and adds a new heading.

9903.82.01 Reintroduced

  • Applies to articles under subdivision (c) of U.S. Note 16
  • Covers goods that do not contain any aluminum, steel, or copper
  • These goods are not subject to Section 232 duties, since the proclamation applies only to covered metal articles and derivatives
  • Duty rates: No change under General, Special, and Column 2

Changes to U.S. Note 16

  • Subdivision (a) now includes 9903.82.01 alongside existing headings
  • Subdivision (e) removes a sentence referencing 9903.82.06 to correct scope and avoid overlap
  • Aligns coverage with subdivisions (c)(ii), (iv), and (vi)–(viii)

These changes apply to entries for consumption, or withdrawals from warehouse, on or after April 6, 2026 (12:01 a.m. ET)

Transitional Rates: January 1, 2028 Changes

Headings 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 apply only to goods entered before January 1, 2028. From that date, goods currently covered by those headings will fall under 9903.82.05, 9903.82.06, and 9903.82.09 (standard Annex I-B rates). CBP will issue additional guidance before that date.

CBP Filing Requirements

Please refer to the full CBP Guidance – CSMS # 68253075.

Country of origin reporting
Importers must continue to report countries of melt and pour for all subject steel and steel derivative products, and countries of smelt and cast for all subject aluminum and aluminum derivative products (see CSMS messages 64348411, 64348288, and 65340246). CBP will issue a separate CSMS message when reporting of copper smelt and cast countries is required and functionality is available in ACE. This applies to copper products under HTSUS: 8544.42.10; 8544.42.20; 8544.42.90; 8544.49.10.

Low metal content articles (Annex II / 9903.82.03)
When claiming the 0% rate under 9903.82.03, report the aggregate weight of the applicable metal(s) in kg as a second quantity on the entry summary line. This heading is not available for articles classifiable in Chapters 72, 73, 74, or 76.

Chapter 98 and Chapter 99 Provisions

Goods entered under a Chapter 98 provision remain eligible for and subject to those terms, except that duties under 9802.00.60 are assessed on the full value of the imported article. No Chapter 99 provision that sets a lower rate or provides duty-free treatment may be claimed. All antidumping, countervailing, or other applicable duties continue to apply.

FTZs and Drawbacks

Covered products admitted to a U.S. FTZ on or after April 6, 2026 must enter under “privileged foreign status” as defined in 19 CFR 146.41, unless eligible for domestic status (19 CFR 146.43). Products admitted under privileged foreign status prior to the effective date will be subject to applicable ad valorem duties upon entry for consumption.

Manufacturing drawback under 19 U.S.C. 1313(a)–(b) is available for Annex I-B and Annex III articles that are products of Trade Agreement Partners (currently the UK, EU, Japan, South Korea, Mexico, Canada, and any future reciprocal partners), where the metal content was smelted or cast in a Trade Agreement Partner country and the article is not subject to antidumping or countervailing duty orders.

Importer Action

Importers should review Annexes I-A, I-B, II, and III & IV against their product classifications and prepare for the April 6, 2026 effective date. Specifically:

  • Identify products that may qualify for the 10% U.S.-origin metal rate and prepare documentation for CBP.
  • Confirm whether any products previously covered as low-metal-content derivatives now fall into a higher annex.
  • Update ACE entries to reflect Chapter 99 heading changes, particularly for products transitioning between headings at January 1, 2028.
  • Monitor forthcoming CBP CSMS guidance on copper smelt/cast country reporting.
  • Review FTZ admissibility procedures for covered goods.

The information presented is general in nature, and is not intended to constitute legal advice with respect to any event or occurrence, and may not be considered as such.​​ Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.​ Due to the complexity of Customs Regulations, valuations are based on information currently available and should not be considered binding, we recommend obtaining National Customs Rulings in areas of uncertainty.​

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