The Administration has announced a significant overhaul to the Section 232 tariff regime covering steel, aluminum, and now copper. This is not a minor adjustment, but rather a structural reset of how Section 232 tariffs are applied.
Key Takeaways
- Tariffs now apply to full product value, not just the metal content
- A new “winners vs. losers” framework has been introduced through annex-based classifications
- Depending on your product mix, this change may result in either meaningful cost savings or increased duty exposure
Effective Date
All changes take effect April 6, 2026, at 12:01 a.m. ET, and apply to:
- Entries for consumption
- Warehouse withdrawals
New Section 232 Framework
The updated regime can be understood in three categories:
- Annex II (Excluded Goods): 0% duty
- Derivative Articles: 25% duty (applied to full value)
- Primary Metals: 50% duty (applied to full value)
Derivative Articles – Key Change
For products that remain subject to Section 232 as derivative articles:
- Tariffs are now applied at 25% of the full product value
- No longer limited to the metal content portion
Examples include:
- Cookware (HTS 7323.xx)
- Knives (HTS 8211.xx)
- Engine components (HTS 8409.xx)
Remaining Planning Lever
With this structural change, companies are left with a single mitigation strategy:
- Material Composition Threshold: Products containing ≤15% (by weight) of steel, aluminum, or copper are not subject to Section 232 tariffs
Note: There is currently no formal guidance on how to calculate metal content, introducing a degree of ambiguity. The trade industry is hopeful that this will be addressed via CBP’s implementation instructions.
Recommended Actions
- Map imported products to the applicable annex using HTS classification
- Identify available industry carve-outs and exemptions
- Evaluate metal content for products potentially below the 15% threshold
- Flag qualifying products as exempt from Section 232
- Update landed cost models to reflect new duty exposure
- Communicate applicable exemptions and treatment to impacted departments
Closing Thoughts
This overhaul introduces both opportunities and risks depending on your product profile. A proactive review of classifications, material composition, and end-use will be critical to managing cost exposure under the new framework.
If you would like assistance assessing the impact on your imports or identifying potential mitigation strategies, please reach out to our CHB and Global Trade Consulting teams.
- Michael Marcovecchio – VP, CHB,
- Michael Padovano – SVP, Global Trade,