Authors:

Jennifer Diaz, President, Diaz Trade Law
Amber Pirson, Attorney, Diaz Trade Law

On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Key elements include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, effective at 12:01 am on April 6, 2026; and manufacturing drawback claims.  

Generally, tariffs will be assessed to the full value of imported products, “regardless of their metal content,” with reduced rates for certain products from the United Kingdom (UK) and the same 200% ad valorem duty for subject metal articles from Russia. 

  • Aluminum and steel articles, most copper articles, and certain derivative articles of aluminum and steel…  
    • 50%, unless either the 25% or 10% rates listed below can apply. 
      • 25% for UK products, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the UK, or the steel content of which is composed entirely of steel that was melted and poured in the UK. 
      • 10% for derivative articles, steel or copper content, when the metal content was smelted and cast in the U.S. 
  • For certain copper and aluminum or steel derivative articles (Annex I-B)…  
    • 25%, unless either the 15% or 10% rates listed below can apply. 
      • 15% for aluminum or steel products of the UK, if smelted and cast or melted and poured in the UK. 
      • 10% for steel or copper content, when the metal content was smelted and cast in the U.S. 
  • For imports listed in Annex III to this proclamation, and entered between April 6, 2026, and December 31, 2027… 
    • Rate determined by the product’s current ad valorem duty under Column 1, unless the 10% or 25% rate listed below can apply. For Column 1 duties < 15%, the additional Sec. 232 duty must be such that the sum of both is 15%. For Column 1 duties ≥ 15%, the additional Sec. 232 duty is 0%.  
      • 10% for derivative articles or steel content, when the former was smelted and cast in the US or when the latter was melted and poured in the US. \
      • 25% for imports from trading partners without normal trading relations with the U.S. (i.e., Cuba, North Korea, Russia, Belarus).  
  • For imports listed in Annex III to this proclamation, and entered on or after January 1, 2028… 
    • The rate schedule applied to products listed in Annex I-B 
  • Additional product-specific rules for articles or derivatives of more than one metal.  
Products Exempt from Sec. 232 Steel and Aluminum Derivatives 
  • Certain items under the following chapter headings, including certain motorcycle parts: 2, 21, 27, 28, 29, 30, 32, 33, 34, 35, 38, 39, 73, 84, 85, 87, 94, and 95. (Annex II) 
Manufacturing drawback claims are available for articles that meet the following four criteria: 
  • Those classifiable in an HTS listed in Annex I-B or Annex III, or later determined by the Secretary and the Trade Representative; 
  • Not subject to an antidumping or countervailing duty order; 
  • A product of Trade Agreement Partners (TAP), which is composed of the United Kingdom, the European Union, Japan, the Republic of Korea, Mexico, Canada, and any trading partner with which the United States concludes a final Agreement on Reciprocal Trade; and 
  • The aluminum and copper were smelted and cast, and the steel was melted and poured in a TAP country.  

 

On April 3, 2026, CBP issued guidance providing instructions for submitting entries to CBP on certain steel, aluminum, and copper articles and their derivatives. See here.

See annexes here. 

View the guide for navigating new Chapter 99 Headings here. 

Learn more: 

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