Changes To Section 232
- IFF, inc.
- Apr 8
- 5 min read
President Trump modified Section 232 for steel, aluminum, and copper and their derivatives. Effective with respect to goods entered for consumption or withdrawn from a warehouse for consumption on or after 4/6/26 (12:01 am ET), the additional duty imposed on goods subject to Section 232 will “apply to the full customs value of the imported product, regardless of metal content”.
Importers will pay:
A flat 50% duty on the full value of articles made entirely or almost entirely of aluminum, steel, or copper. An example of articles are steel coils and aluminum sheets.
A flat 25% on their full value of derivative articles substantially made of steel, aluminum, or copper.
Fifteen percent through 2027 for certain metal-intensive industrial equipment and electrical grid equipment.
Ten percent on products made abroad but entirely with American steel, aluminum, and copper.
Zero Section 232 tariffs on products made of 15% or less steel, aluminum, or copper. These goods will not be subject to Section 232.
For articles listed in Annex I-A of the executive order Section 232 duties are:
Fifty percent unless one of the 2 below duty rate apply.
Twenty-five percent for articles of the United Kingdom when the aluminum content is entirely composed of aluminum smelt or most recently cast in the United Kingdom or the steel content entirely composed of steel melted and poured in the United Kingdom. At least 95% of the aluminum must be smelted or cast in the United Kingdom.
Ten percent for derivative articles when the aluminum content is entirely composed of aluminum smelt and cast in the United States, the steel entirely composed of steel melted and poured in the US, or copper entirely composed of copper smelted and cast in the US.
For articles listed in Annex I-B (Page 13) of the executive order Section 232 duties are:
Twenty-five percent unless one of the 2 below duty rates apply.
Fifteen percent articles of the United Kingdom when the aluminum content is entirely composed of aluminum smelt or most recently cast in the United Kingdom or the steel content entirely composed of steel melted and poured in the United Kingdom. At least 95% of the aluminum must be smelted or cast in the United Kingdom and 95% of the steel must be melted and poured in the United Kingdom.
Ten percent for articles when the aluminum content is entirely composed of aluminum smelt and cast in the United States, the steel entirely composed of steel melted and poured in the US, or copper entirely composed of copper smelt and cast in the US.
Articles listed in Annex II (Page 29) of the executive order are not subject to Section 232.
For articles listed in Annex III (Page 40) of the executive order the Section 232 duties are effective until 12/31/27 (11:59 pm ET).
The Section 232 duties for items listed in Annex III are determined based on the product’s column 1 duty rate unless one of the below lower or higher duty rates apply.
If the column 1 duty rate is less than 15%, the sum of the column 1 duty rate and the Section 232 duty rate is 15%.
If the column 1 duty rate is at least 15%, the Section 232 duty rate will be zero.
Ten percent for derivative articles when the aluminum content is entirely composed of aluminum smelt and cast in the United States, the steel entirely composed of steel melted and poured in the US, or copper entirely composed of copper smelt and cast in the US. The 10% us determined based on the column 1 duty rate.
If the column 1 duty rate is less than 10%, the sum of the column 1 duty rate and the Section 232 duty rate is 10%.
If the column 1 duty rate is at least 10%, the Section 232 duty rate will be zero.
Twenty-five percent for products imported from trading partners with whom the US doesn’t normally maintain trading relations.
If President Trump or the United States Trade Representative (USTR) determine that imports of derivative articles listed in Annex III from a particular country have increased in a manner that undermine the purpose of the executive order, the President or the USTR may revoke that country’s eligibility to have those derivative articles enter the US at the preferential rates currently provided to articles listed in Annex III. If this determination is made, the Section 232 duty rate for goods of that country will be the same as the rate currently applied to goods listed in Annex I-B.
Effective 1/1/28, imports of products listed in Annex III will be subject to a different Section 232 duty rate. The duty will be the same as the Section 232 rates currently applied to goods listed in Annex I-B.
Products of Russia listed in Annex I-A, Annex I-B, or Annex III or where the primary aluminum used to manufacture the product was smelted or cast in Russia are subject to 200% Section 232 duties.
Articles of steel or copper or their derivatives of Russia are subject to Section 232 duties of 10%, 25%, or 50% depending on the HTS code.
Articles listed in Annex I-B (Page 13) or Annex III (Page 40) that do not contain any aluminum, steel or copper are not subject to Section 232 duties.
Products listed in Annex I‑B (Page 13) or Annex III (Page 40) that are not classified in chapters 72, 73, 74, or 76 of the HTSUS, and the weight of the aluminum, steel, or copper content is less than 15% are not subject to Section 232 duties. You must report the aggregate weight of the applicable metal in kg as a second quantity on the entry line.
Goods listed in Annex I-A, Annex I-B (Page 13), and Annex III (Page 40) containing more than one of the covered metals—aluminum, steel, or copper—will be subject to Section 232 duties only once, even if the product includes any combination of the metals (aluminum and steel, aluminum and copper, steel and copper, or all three).
Motorcycle parts classifiable in chapter 84, 85, or 87 used in manufacturing motorcycles in the US are not subject to Section 232.
This executive order does not change or replace prior agreements with the United Kingdom, Japan, the Republic of Korea, the European Union, or any other trading partner to reduce Section 232 tariffs on certain imports of aluminum, steel, or copper and their derivatives.
Per the executive order “This authority shall allow metal containers to be included in the scope of the metal tariffs, even if they are filled with items that will not be subject to steel, aluminum, or copper tariffs.”
The USTR and the Secretary may add new derivative articles to the list of articles subject to Section 232 if they determine that imports of the derivative aluminum, steel, or copper article threaten to impair national security, contribute to national security risks, or undermine the objectives of the executive order. Articles added to the list will be subject to the duty rates currently applied to goods listed in Annex I-B unless the articles are identical or “substantially comparable” to products listed in Annex I-A. If the goods are identical to or comparable with goods listed in Annex I-A, the Section 232 duty rate will be the same as the rate currently applied to Annex I-A.
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