New Section 232 Proclamation Overhauls Tariffs on Steel, Aluminum, and Copper Products
On April 2, 2026, the President issued a sweeping new proclamation modifying existing Section 232 tariff regimes on steel, aluminum, and copper imports. The changes represent one of the most significant expansions of these tariffs since their initial implementation in 2018 and will have immediate implications for importers, manufacturers, and supply chains.
The new measures take effect for goods entered on or after April 6, 2026.
Tariffs Now Apply to Full Customs Value
A key change in the proclamation is that Section 232 tariffs will now apply to the full customs value of imported products, rather than being limited to the value of the metal content.
This applies to:
- Aluminum articles
- Steel articles
- Copper articles
- Derivative products containing these metals
This shift significantly increases the effective duty burden for many importers, particularly those importing downstream or composite products.
Increased Tariff Rates: Up to 50%
The proclamation establishes new tariff rates for covered products:
- 50% ad valorem duties on most steel and aluminum articles, certain copper products, and specified derivative goods
- 25% duties on other copper products and certain derivative articles
- Reduced rates for certain products from the United Kingdom and for goods made entirely from U.S.-origin metals
These rates represent a substantial increase from prior Section 232 duty levels and reflect a continued focus on strengthening domestic metal industries.
Elimination of Inclusion Process and Expanded Government Authority
The proclamation terminates prior product inclusion processes for derivative articles and replaces them with a new framework:
- The Department of Commerce and the U.S. Trade Representative are now authorized to add products to the tariff scope on a rolling basis
- Additions may occur where imports are deemed to undermine national security objectives or circumvent existing tariffs
This change introduces greater uncertainty for importers, as additional products may become subject to tariffs without a formal inclusion request process.
Changes to Scope of Derivative Articles
The administration also revised which derivative products are subject to tariffs:
- Some products have been removed from coverage
- Others remain or may be newly included to prevent tariff circumvention or address national security concerns
Importers should carefully review updated annexes to determine whether their products remain covered.
Special Rules for Certain Imports
The proclamation includes several notable provisions:
- Russian aluminum products remain subject to a 200% tariff
- Certain goods may qualify for lower rates based on origin (e.g., UK or U.S.-origin metal content)
- Products containing multiple metals are generally subject to only one applicable tariff
- Goods lacking sufficient metal content may be excluded from duties
Temporary Tariff Framework for Certain Products
For certain listed products, a temporary tariff regime applies through December 31, 2027, under which:
- Duties are tied to existing HTSUS rates, with a minimum combined rate of 15%
- Higher rates may apply to imports from countries without normal trade relations
After January 1, 2028, these products will transition to the standard tariff structure.
Increased Compliance and Enforcement Focus
CBP is authorized to take enhanced enforcement measures, including:
- Requiring detailed reporting on smelting and casting origins of metals
- Targeting transshipment, undervaluation, and tariff evasion schemes
- Issuing guidance and regulations to implement the new rules
These requirements will increase compliance burdens and documentation obligations for importers.
Key Takeaways for Importers
- Duty exposure will increase significantly, especially for derivative products
- Tariffs now apply to full product value, not just metal content
- Product scope may change dynamically, with limited notice
- Compliance obligations are expanding, particularly around origin reporting