Section 232 tariffs on base metals

Purpose

The President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” which imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles), and their derivatives from all countries, effective 6 April, 2026.

What is changing?

• Expanded Scope: Applies to a wide range of metal articles and derivative products from all countries.
• Duty Rates: 50% for primary metals, 10%-25% for “derivative” products.
• No stacking: Products containing multiple metals (e.g., aluminum and steel, or copper) are subject to only a single duty rate.
• Duty base: The applicable rate applies to the entire value of the product, leaving behind the concept of “metal content”, which was challenged in court a couple of months ago.

Exemptions:

• Certain (derivatives) items with less than 15% of metal content are now exempt from these tariffs.
• Goods listed in annexes that contain no aluminum, steel, or copper.
• Certain Motorcycle parts are used in US Manufacturing.

Country Specific Rates

Aluminum, steel, and copper products from the United Kingdom are subject to reduced rates (15%-25%) when 95% of the metal is poured, melted, or smelted in the UK.

Considerations for all importers:

• Verify if your classification appears in the Section 232 listings: Metals HTS LIST 040326.docx
• Identify the weight percentage of aluminum, steel, or copper and reflect it in your commercial documents.
• Declare the country of smelt and pour.
• Declare the correct value of the product.