Section 232 April 6, 2026 Proclamation Update – Steel, Aluminum & Copper Importer Factsheet

Additional Resources:

Proclamation | Fact Sheet | Annex Lists (Breakout by HTSUS#)

---

The Administration has issued a new proclamation modifying the Section 232 tariff framework for steel, aluminum, copper, and derivative products. This represents a structural change in how duties are calculated and enforced. The Administration is using a tiered tariff system, being 50%, 25%, 15%, 10% & exempt. 

• Core Products - Commodity (Upstream) Metals at 50% of full entered value

  50% ad valorem tariff remains in place for:  

  • Steel  

  • Aluminum  

  • Copper  

  • Applies to primary metal products (e.g., bars, plates, coils, etc.)  

  • No change to base rate structure  

  • Deductions not allowed for partial US steel/aluminum/copper

  Note: HTSUS Listed on Annex I-A pages 1–12

• Derivative / Finished Products at 25% of full entered value

  • New tariff rate (generally 25%) applies to many derivative goods.

  • Applies to finished or downstream products containing these metals.

  • Duty is now assessed on the full value of the product.

  Shift from prior methodology:

  • Previously: duty applied to metal content value only.

  • Now: duty applies to entire entered value of the finished product.

  • Deductions not allowed for partial US steel/aluminum/copper.

  Note: HTSUS Listed on Annex I-B pages 13–28

• Temporary Relief for Certain metal intensive industrial & electrical grid equipment at 15% until December 2027

  Includes some:

  • Industrial goods

  • Machinery

  • Consumer products

  • Infrastructure-related equipment

  Importers should:

  • Verify the accuracy of a products HTSUS# (prior to entry).

  • Check the updated Annex III for HTSUS applicability.

  Note: HTSUS Listed on Annex III pages 40–42

• Products made abroad, but entirely with American steel, aluminum & copper at 10%

  • All steel/aluminum/copper content in said product must be 100% of US steel/aluminum/copper (melt/pour & smelt/cast).

  • If product isn’t composed entirely of steel/aluminum/copper of the US, the applicable Section 232 rate applies.

• Products made of 15% or less of steel, aluminum or copper no longer subject

  • Products with less than ~15% metal content (by weight).

  • Not subject to Section 232 derivative tariffs.

  Importer impact:

  • Requires content screening at product level.

  • Creates a new eligibility test for mixed-material goods.

  • Importers should keep records on products claimed of material, weight & values.

• United Kingdom carve outs at 25% & 15%, respectively

  • 25% for Core Products of aluminum or steel products of the UK.

  • 15% for Derivate Products of aluminum or steel product of the UK.

  Note: HTSUS Listed on Annex IV

• Items removed from scope of Section 232 Steel & Aluminum Derivatives

  • Numerous steel & aluminum derivatives were removed from Section 232.

  • Tariff numbers removed located on Annex II.

  Note: HTSUS Listed on Annex II pages 29–34

(Critical Change) New Valuation Methodology

Section 232 duties may now be calculated based on:

• U.S. sales price / transaction value downstream

• Not strictly the declared customs value

Designed to address:

• Undervaluation concerns

• Transfer pricing manipulation

Enforcement Changes

The proclamation introduces a stronger enforcement posture:

• Focus on:

  • Undervaluation

  • Misclassification

  • Circumvention via content manipulation

• Structural fix:

  • Moving from content-based to full-value tariff model reduces manipulation risk.

Expect:

• More audits

• More CF-28 / CF-29 activity

• Greater documentation requirements

Effective Date

Changes take effect shortly after issuance (April 6, 2026 12:01 a.m. eastern daylight time)

Applies to:

• Entries for consumption

• Withdrawals from warehouse

---

This document reflects a high-level business review of the updated Section 232 framework and is intended for general informational purposes only. It does not cover all scenarios, exceptions, or product-specific applications, and should not be relied upon as legal or regulatory advice.

Importers are encouraged to conduct a detailed review of their specific entries and consult with Juno Customs Solutions (JCS) for guidance.

We can be reached through your filing representative or via email at brokerage@junocustoms.com