Annex IV Update – New Section 232 Duty Provisions for Certain Steel, Aluminum, Copper, and Equipment-Related Articles

Jun 4

Effective Date: June 8, 2026

Annex IV modifies Subchapter III of Chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS) for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on June 8, 2026.

The changes primarily affect certain derivative steel articles, derivative aluminum articles, copper articles, and selected parts used in agricultural, fixed industrial, and mobile industrial equipment.

What Changed?

Annex IV expands and reorganizes portions of U.S. Note 16 and adds new Chapter 99 tariff headings, 9903.82.20 through 9903.82.26.

These headings establish separate duty treatment based on factors including:

Article type
Country of origin
Eligibility under the United States-Mexico-Canada Agreement (USMCA)
U.S. content value
Applicable Column 1 duty rate

A significant change is the creation of a new category for certain derivative steel articles under U.S. Note 16(c)(xi). Covered products include certain forklifts and works trucks, construction and earthmoving equipment, machinery parts, tractors, crane lorries, drilling derricks, and other products classified under specified HTSUS provisions.

New Chapter 99 Headings

Countries/Origin Applicability
- Mexico or Canada, where the article is USMCA-eligible.
General Effect
- Applies to certain USMCA-eligible derivative steel articles. The duty applies to the non-U.S. content, and to U.S. content exceeding 40% of the article’s value. Rate: applicable duty plus 25%.
Countries/Origin Applicability
- Mexico or Canada, where the article is USMCA-eligible.
General Effect
- Applies to qualifying U.S. content not exceeding 40% of the value of certain USMCA-eligible derivative steel articles. Rate: No change.
Countries/Origin Applicability
- Argentina
- Ecuador
- El Salvador
- Guatemala
- Japan
- Republic of Korea
- Liechtenstein
- Switzerland
- Taiwan
- United Kingdom
- European Union member countries
General Effect
- Applies to certain derivative steel articles from the listed countries. Rate: 15%.
Countries/Origin Applicability
- All countries except General Note 3(b) countries, where the article meets U.S. Note 16(e) and 16(k), and Column 1 duty is below 10%.
General Effect
- Applies to qualifying copper articles, derivative aluminum articles, and derivative steel articles. Total duty is brought to 10%.
Countries/Origin Applicability
- All countries except General Note 3(b) countries, where the article meets U.S. Note 16(e) and 16(k), and Column 1 duty is 10% or higher.
General Effect
- Applies to similar qualifying articles with Column 1 duty rates equal to or above 10%. Rate:No additional change.
Countries/Origin Applicability
- All countries except General Note 3(b) countries, where the article meets U.S. Note 16(k) but does not meet U.S. Note 16(e), and Column 1 duty is below 15%.
General Effect
- Applies to qualifying copper articles, derivative aluminum articles, and derivative steel articles that do not meet the requirements of U.S. Note 16(e). Total duty is brought to 15%.
Countries/Origin Applicability
- All countries except General Note 3(b) countries, where the article meets U.S. Note 16(k) but does not meet U.S. Note 16(e), and Column 1 duty is 15% or higher.
General Effect
- Applies to similar articles with Column 1 duty rates equal to or above 15%. Rate:No additional change.

Annex IV provides that tariff headings 9903.82.20 and 9903.82.21 apply to certain USMCA-eligible derivative steel articles, while 9903.82.22 applies to derivative steel articles from specifically identified countries.

The annex also states that headings9903.82.23 through 9903.82.26 do not apply to products of countries identified in General Note 3(b) of the HTSUS.

USMCA Valuation Requirement

For certain USMCA-eligible derivative steel articles, importers must identify the amount of U.S. content contained in each imported article.

Annex IV defines U.S. content as the value attributable to parts produced in the United States. Non-U.S. content is calculated by subtracting the U.S. content value from the total value of the imported article.

U.S. Customs and Border Protection (CBP) may require supporting documentation in a format it determines appropriate. Importers claiming this treatment should be prepared to substantiate U.S.-content calculations with supplier documentation and supporting records.

Parts Used in Agricultural, Fixed Industrial, or Mobile Industrial Equipment

Annex IV also adds new U.S. Note 16(k).

This provision covers certain parts classified in Chapters 84, 85, or 87 that will be used exclusively in the manufacture of agricultural equipment, fixed industrial equipment, or mobile industrial equipment identified within the note.

Depending on the applicable requirements and Column 1 duty rate, these parts may be subject to tariff provisions 9903.82.23 through 9903.82.26.

Aluminum Content Threshold Change

Annex IV lowers the aluminum-content threshold in U.S. Note 16(e) from 95% to 85% wherever it appears.

This change may affect the application of certain derivative aluminum provisions under the modified note.

Temporary Nature of the New Provisions

The new Chapter 99 provisions are temporary.

Effective January 1, 2028, tariff provisions 9903.82.20 through 9903.82.26 will be removed from the HTSUS, and related U.S. Note references will revert to their prior structure.

Recommended Actions for Importers

Importers should review current and upcoming shipments that may fall within the HTSUS provisions added to or modified under U.S. Note 16, particularly:

Machinery
Industrial equipment
Tractors
Industrial vehicles
Equipment parts
Derivative steel articles
Derivative aluminum articles
Covered copper articles

For potentially affected products, importers should confirm:

Full 10-digit HTSUS classification
Country of origin
Material composition, including steel, aluminum, copper, or derivative content
USMCA eligibility, where applicable
Whether U.S. content must be separately identified
Whether parts are used exclusively in agricultural, fixed industrial, or mobile industrial equipment
Applicable Chapter 99 reporting requirements at entry

Documentation Considerations

Because duty treatment under Annex IV depends on classification, material composition, intended use, country of origin, USMCA eligibility, and U.S.-content valuation, importers should obtain supporting documentation before entry whenever possible.

Key Takeaway

Beginning June 8, 2026, Annex IV introduces new Chapter 99 reporting and duty requirements for certain steel, aluminum, copper, machinery, vehicle, and equipment-related imports.

Importers with potentially affected products should review classifications, sourcing, and supporting documentation in advance to ensure compliance with the new reporting requirements and applicable duty treatment.

For questions regarding these changes, please contact Juno Customs Solutions at brokerage@junocustoms.com.

Steve Perez