Section 232 Changes for Aluminum, Copper and Steel

On April 2, 2026, the White House issued a presidential proclamation that significantly changes how Section 232 tariffs will be applied to aluminum, steel, and copper goods. For importers, this creates both risk and opportunity. Some shipments may now face higher duties based on full customs value, while others may qualify for new exemptions or reduced rates depending on metal content, classification, or country of origin.

In this blog, we’ll break down what’s changed, how the new annex structure impacts tariff rates, where exemptions may apply, and what importers should review now to stay compliant and avoid overpaying.

Section 232 tariffs on full customs value

Articles and derivatives subject to Section 232 metals will now face an additional tariff on the full customs value of goods. Importers can no longer break out values based on metal and non-metal content, as the previous proclamation permitted.

Tariff rate dependent on specific tariff annexes

The revised proclamation included the Metals Annexes, which detailed what HTS numbers will be subject to Section 232 as well as the specific tariff rate that is applicable. If an item contains both steel and aluminum, then it will only be subject to one of the respective tariffs. Previously, an importer had to report and pay steel and aluminum tariffs separately even if they were a single item.

Annex 1A – 50% tariff rate: These goods are either entirely or almost entirely made of metal.
Annex 1B – 25% tariff rate: These goods contain a substantial amount of metal or are a derivative article.

Goods that do not contain any of the metals will not be subject to Section 232 tariffs.

Fifteen percent minimum content requirement

The new guidance also stipulates that if an article contains less than 15% of the aggregate weight of the applicable metal, then it will not be subject to Section 232 duties, except if the goods are classified in chapters 72–74 or 76.

If the good contains both steel and aluminum, and the tariff is flagged for both metals for Section 232, then the importer must take the aggregate weight of both metals to determine if it is less than 15% by weight.

Importers should review their commodities closely to see if they qualify for this exemption; however, they need to be able to fully support the claim if CBP requests documentation with bills of materials and product specification data.

Tariffs removed and other exemptions

In addition to structural changes to how tariffs are applied, the proclamation also removes Section 232 duties from certain products and introduces new exemptions. Key changes include:

Section 232 tariffs are no longer applicable to a large list of HTS numbers that had been derivative products, including beer, paint, cosmetics, furniture and other commodities where steel or aluminum had been incorporated into packaging.
Motorcycle parts classified in chapters 84, 85 and 87 and imported for the sole purpose of manufacturing in the United States is now fully exempted from Section 232 steel or aluminum tariffs.
Temporary reductions on a specific “metal intensive equipment” have been granted through December 31, 2027.
Civil aircraft parts eligible under “Trade in Civil Aircraft” agreement are exempted from the tariffs if manufactured in UK, European Union, South Korea or Japan.

Country-specific tariff rates

The proclamation also introduces updated, country-specific tariff treatments that may override standard Section 232 rates depending on origin and metal content. These provisions add another layer of complexity for importers sourcing globally. Changes include:

United States: Goods manufactured abroad with 95% or higher amounts of U.S. origin steel, aluminum or copper will be subject to a 10% tariff. Goods were previously exempt from Section 232 if the steel or aluminum were of U.S. origin.
United Kingdom: The United Kingdom will receive a reduced rate (15-25% depending on Annex 1A or 1B) if the goods are at least 95% of UK origin metal content.
Russia: While aluminum products continue to be subject to 200%, Russia origin steel and copper goods will be subject up to 50%.
Column 2 countries: Countries that do not have normal trade relations with the United States will be subject to 25%.

Importers should review their product classifications, bills of materials, and sourcing strategies in light of these changes. The shift to full customs value, new annex-driven rates, and expanded exemptions means even small classification or documentation gaps could result in overpayment—or compliance risk.

Now is the time to validate how your goods are classified, confirm metal content thresholds, and identify where exemptions or reduced rates may apply. Reach out to your customs broker for assistance in interpreting these requirements and changes.