Upcoming Section 232 Changes Impacting Steel, Aluminum, and Copper Imports

A new presidential proclamation titled "Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper into the United States" introduces significant changes to Section 232 duties affecting a broad range of imported products. While additional guidance from U.S. Customs and Border Protection (CBP) is expected, importers should begin preparing for the changes outlined below.

Key Changes Effective June 8, 2026

For goods entered for consumption, or withdrawn from warehouse for consumption, on or after June 8, 2026, at 12:01 a.m. Eastern Time, Annexes I-A, I-B, II, and III will be modified as provided in Annex IV of the proclamation.

The proclamation temporarily adjusts Section 232 tariffs on:

• Certain metal-based agricultural equipment

• Certain residential heating, ventilation, and air conditioning (HVAC) systems and components

• Certain machinery and mobile industrial equipment, including bulldozers and forklifts

• Aluminum lithographic plates

• Steel racks

These products are identified in Annex I-C and will be subject to special tariff treatment through December 31, 2027.

Section 232 Duty Rates for Annex I-C Products (June 8, 2026 – December 31, 2027)

General Rule

For aluminum and steel articles listed in Annex I-C, the Section 232 duty rate will generally be 25%, unless a lower rate applies based on country of origin or the applicable Column 1 duty rate.

Key provisions include:

• The Section 232 duty applies to the full value of the product through December 31, 2027.

• Products containing multiple covered metals will only be assessed one Section 232 duty rather than cumulative duties for each metal.

  
  

Special Treatment for Certain Countries

Products originating in:

• Argentina

• Ecuador

• El Salvador

• Guatemala

• Japan

• Republic of Korea

• Liechtenstein

• Switzerland

• Taiwan

• United Kingdom

• European Union member states

will receive modified treatment based on the Column 1 duty rate:

• If the Column 1 duty rate is less than 15%, the combined Column 1 and Section 232 duties will equal 15%.

• If the Column 1 duty rate is 15% or greater, no additional Section 232 duty will apply.

  
  

U.S.-Produced Steel and Aluminum Content

Derivative products listed in Annex I-C that are:

• Entirely composed of aluminum smelted or cast in the United States, or

• Entirely composed of steel melted and poured in the United States

will be subject to a maximum effective duty rate of 10%.

Specifically:

• If the Column 1 duty rate is less than 10%, the combined duty rate will equal 10%.

• If the Column 1 duty rate is 10% or greater, no Section 232 duty will apply.

USMCA Treatment for Canada and Mexico

For products originating in Canada or Mexico that qualify for preferential treatment under the USMCA:

• The 25% Section 232 duty will apply only to the non-U.S. content.

• Non-U.S. content is defined as the total value of the product minus the value attributable to parts produced in the United States.

However, the proclamation establishes a minimum effective duty rate:

• The total effective duty assessed on the imported product may not be less than 15% ad valorem.

The Secretary of Commerce will provide additional guidance to CBP regarding the determination and calculation of U.S. content.

Changes Effective January 1, 2028

Beginning January 1, 2028, at 12:01 a.m. Eastern Time, products listed in Annex I-C will transition to the permanent Section 232 tariff structure established under Proclamation 11021.

Standard Rate

The default Section 232 duty rate will be 25%, unless a reduced rate applies.

United Kingdom Products

A reduced 15% duty rate will apply to qualifying products from the United Kingdom when:

• Aluminum content is entirely composed of aluminum smelted or most recently cast in the United Kingdom, or

• Steel content is entirely composed of steel melted and poured in the United Kingdom.

At least 95% of the aluminum content must be smelted or cast in the United Kingdom to qualify.

U.S.-Origin Metal Content

A reduced 10% duty rate will apply when:

• Aluminum content is entirely composed of aluminum smelted and cast in the United States;

• Steel content is entirely composed of steel melted and poured in the United States; or

• Copper content is entirely composed of copper smelted and cast in the United States.

Additionally, the threshold for products to qualify as being composed entirely of U.S. aluminum, steel, or copper will be lowered from 95% to 85%.

Multiple Metal Products

For products subject to Section 232 treatment for more than one covered metal, the lowest applicable Section 232 duty rate will apply.

What Importers Should Do Now

Importers should review Annex I-C carefully to identify affected products and evaluate potential impacts on sourcing strategies, landed costs, and customs compliance. Companies importing machinery, agricultural equipment, HVAC products, steel racks, aluminum lithographic plates, or products containing multiple covered metals should pay particular attention.

Additional implementation guidance from CBP is expected through future Cargo Systems Messaging Service (CSMS) notices, which should provide further clarification on reporting requirements, tariff calculations, and treatment of U.S. content under these new rules.