Trump Overhauls Section 232 Tariffs on Steel, Aluminum, and Copper

April 8, 2026

Trump Overhauls Section 232 Tariffs on Steel, Aluminum, and Copper

Ngosong Fonkem Amundsen Davis LLC + Follow Contact LinkedIn Facebook X Send Embed On April 2, President Trump issued a new presidential proclamation adjusting his earlier issued section 232 tariffs on steel, aluminum, copper, and their respective derivative products. The changes went into effect on April 6 and alter how these tariffs are assessed and calculated.

Key Changes to Section 232 Tariffs

The “adjustments,” which are specifically provided in the accompanying Annexes I-A, I-B, II, III & IV, provide as follows:

• Articles made entirely or almost entirely of aluminum, steel, or copper in Annex 1-A shall now be assessed a tariff rate of 50 percent and based on the full commercial value of the article. The only exception to this rule is: if the article is produced from UK steel/aluminum/copper, then it is assessed 25 percent tariff rate.
• Derivative articles that are substantially made of steel, aluminum, or copper and found in Annex 1-B shall now be assessed a tariff rate of 25 percent and based on the full commercial value of the article. The only exception to this rule is: if the article is produced from UK steel/aluminum/copper, then it is assessed 15 percent tariff rate.
• Derivative articles in Annex 1-A that are made abroad and 1) entirely of U.S.-melted/poured steel or U.S.-smelted/cast aluminum and 2) copper shall now be assessed a tariff rate of 10 percent of the full value of the article.
• Products containing 15 percent or less of steel, aluminum, or copper are exempt entirely from section 232 tariffs.
• Some metal-intensive equipment of steel and aluminum derivatives that are listed in Annex III shall now be assessed a tariff rate between 10-25 percent. The rate depends on whether or not the product is made: 1) in a country that has permanent normal trading relations with the U.S. and 2) entirely with U.S.-melted/poured or U.S.-smelted/cast metal. The Annex III treatment will terminate December 31, 2027, and shall be replaced with the applicable Annex I-B rates for the same products.
• For aluminum products smelted or cast in Russia, a 200 percent duty rate shall remain.

What Do These Changes Mean for Importers?

Undoubtedly, for most companies these changes shall significantly impact the duty rate at which they pay for impacted articles and shall result in lower duty rates. Notably, several products that are detailed in Annex II have been removed from the list of derivative articles subject to tariffs, including products that are packaged in steel, aluminum, or copper containers. Examples include milk, chemicals, pharmaceuticals, etc. as well as certain machines and machine parts, motorcycles and their parts, furniture, etc.

With an effective date of April 6, we continue to recommend that importers:

• Review their products’ Harmonized Tariff Schedule of the U.S. (HTSUS) classifications to determine whether any are impacted by these changes and calculate the new duty rate.
• Continue to monitor U.S. Customs and Border Protection (CBP) guidance on the implementation of the new regulation. In the meantime, we will continue to keep you updated should new developments become available.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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