U.S. Adjusts Section 232 Tariffs on Aluminum, Steel and Copper – Full Customs Value Now Applies (Updated)
Trade Update • April 2, 2026 [Updated April 3]
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.
- Inclusions process: Prior process terminated; Secretary of Commerce and USTR authorized to add derivatives on a rolling basis.
- CBP guidance is now available here.
President 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.
Tariffs Calculated
The White House fact sheet 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.
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.
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.
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.
How GHY Can Help?
GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.
By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.
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