Section 232 Tariffs Restructured: New Tiers for Steel, Aluminum, and Copper Derivatives — Effective April 6, 2026
Section 232 Tariffs Restructured: New Tiers for Steel, Aluminum, and Copper Derivatives — Effective April 6, 2026
On April 2, 2026, President Trump signed a proclamation restructuring Section 232 tariffs on steel, aluminum, and copper imports. The changes take effect at 12:01 a.m. on Monday, April 6, 2026 — with no exception for goods already in transit. If your shipments are on the water right now, the new rates apply when they arrive.
This is the most significant structural change to Section 232 since the June 2025 rate increase. The headline rate for pure metal products stays at 50%, but the proclamation introduces a new tiered system for derivative articles and creates a de minimis exemption that removes many mixed-content products from Section 232 scope entirely.
The New Three-Tier Structure
Annex I-A — 50% on full entered value
Articles made entirely or almost entirely of steel, aluminum, or copper fall here. This covers the products most importers associate with Section 232: steel coils, aluminum sheet, copper wire rod, structural beams, and similar primary metal goods. The 50% rate is unchanged from June 2025, but the proclamation now makes explicit that it applies to the full entered value of the shipment — a clarification that matters for any valuation disputes.
Annex I-B — 25% on full entered value (new)
Derivative articles substantially made of steel, aluminum, or copper are now subject to a flat 25% rate applied to the full entered value of the goods. This is a meaningful change. Before this proclamation, derivative tariffs were calculated on the metal content of the article — not the full value. For a fabricated steel component with a full value of $10,000 but a steel content of $4,000, the old calculation was $1,000 in Section 232 duty (25% × $4,000). Under the new rule, the duty is $2,500 (25% × $10,000). That's a 150% increase in actual duty dollars on the same physical product.
Annex III — 15% through December 31, 2027
Metal-intensive industrial equipment and electrical grid equipment receive a temporary 15% rate. This is a concession to sectors where domestic production capacity is being built out. The 15% rate expires at the end of 2027, at which point these products would move to Annex I-A or I-B rates.
The New 15% De Minimis Exemption
Any article outside HTS Chapters 72–76 containing 15% or less of steel, aluminum, or copper by value is now entirely exempt from Section 232. This removes a large category of lightly metal-containing goods from tariff scope — think finished consumer products with minimal metal components. If you import goods that were previously subject to derivative Section 232 duties because of incidental metal content, verify whether the 15% threshold now exempts them.
Special Cases
U.S.-origin metal content: Products manufactured abroad using exclusively American-produced steel, aluminum, or copper are eligible for a 10% rate rather than the standard Annex I-A or I-B rate. This is an incentive mechanism for global manufacturers to source their metal inputs from U.S. producers.
United Kingdom: UK-origin products receive reduced rates of 25% (instead of 50%) and 15% (instead of 25%) under the standing U.S.-UK trade framework.
No in-transit exception: The proclamation explicitly provides no relief for goods already at sea. Entries made on or after April 6, 2026 pay the new rates regardless of when the goods were loaded.
What This Means for Your Landed Cost
Consider a U.S. importer sourcing fabricated steel brackets — a typical Annex I-B derivative product — from Germany. The brackets have a full commercial value of $50,000 and a steel content of roughly $18,000.
Before April 6, 2026 (metal-content basis):** - Section 232 duty: 25% × $18,000 = **$4,500** - Section 122 surcharge: exempt (Section 232 goods are exempt from Section 122 per the Feb 24, 2026 proclamation) - Total duties: ~$4,500 | Effective rate on full value: **9%
After April 6, 2026 (full entered value basis):** - Section 232 duty: 25% × $50,000 = **$12,500** - Section 122: still exempt - Total duties: ~$12,500 | Effective rate on full value: **25%
That's a $8,000 increase in duty on a single $50,000 shipment. Multiply that across annual volume and the budget impact is immediate.
Use our Duty & Tariff Calculator to model your updated landed cost under the new Section 232 structure.
What Importers Should Do Right Now
Classify your products under the new annexes. The proclamation's Annex I-A, I-B, and III product lists map to specific HTS codes. Your customs broker should confirm which annex your products fall under — the difference between Annex I-A (50%) and Annex I-B (25%) is significant, and some products that were previously derivative-duty-eligible may now qualify for the 15% de minimis exemption.
Audit derivative product exposure. If you import finished goods with substantial metal content, assume you are in Annex I-B until confirmed otherwise. Request a formal binding ruling from CBP if your product's classification is ambiguous.
Check in-transit shipments immediately. There is no grace period for goods at sea. If shipments are expected to arrive on or after April 6, recalculate your duty liability and adjust your duty reserve accordingly.
Review supplier agreements. If your contracts include duty escalation clauses or landed cost benchmarks, the Annex I-B change to full entered value may trigger renegotiation rights.
Model the Section 122 expiry alongside these changes. The Section 122 universal 15% surcharge expires July 24, 2026. For Section 232-covered goods (which are already exempt from Section 122), that date doesn't change your duty calculation. But for products that shift into Section 232 scope under the new derivative rules, tracking both the April 6 effective date and the July 24 Section 122 expiry matters for accurate forward modeling.
The Bottom Line
The April 2, 2026 proclamation doesn't change the top-line 50% rate on primary steel and aluminum — but it materially increases the cost of imported derivative articles by switching from a metal-content basis to a full-entered-value basis for the 25% Annex I-B rate. For manufacturers and distributors sourcing fabricated metal components internationally, the effective duty increase on those products can be substantial.
Use our Duty & Tariff Calculator to estimate your updated landed cost under the current Section 232 structure, and check back as we track any further modifications to the annexes.
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