Section 232 tariffs on steel, aluminum and copper: is your product covered?

Section 232 of the Trade Expansion Act of 1962 lets the President adjust imports that threaten national security. Since 2018 it has been used on steel and aluminum, and since August 2025 on copper. For most of 2025 the rules for "derivative" products, such as kitchenware, fasteners or furniture, were built around metal content. That changed in April 2026. If your pricing still assumes duty on the steel content only, it is out of date.

What changed on April 6, 2026

Proclamation 11021, "Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper," was signed April 2, 2026. From 12:01 a.m. Eastern on April 6, 2026, the metals duties apply to the full customs value of the imported product, regardless of how much metal it contains. The same rule now covers steel, aluminum and copper.

A worked example shows why this matters. You import $10,000 of stainless steel kitchenware, and the steel inside is worth $6,000. Under the 2025 rules, a 50% duty on the steel content was $3,000. If the same code is on Annex I-A today, the duty is 50% of $10,000, which is $5,000. The base duty, any Section 301 duty and the fees come on top.

The rate tiers

• Annex I-A, 50%. Steel and aluminum articles, most copper articles and certain derivatives.
• Annex I-B, 25%. Other copper articles and derivatives.
• Annex I-C, 25% by default. Added by Proclamation 11032 from June 8, 2026.
• Annex III, top-up to 15%. Through December 31, 2027, if the normal column 1 rate is under 15%, the 232 duty brings the total to 15%. If the normal rate is already 15% or more, no 232 duty is added. Countries without normal trade relations pay 25%. From 2028 these goods are scheduled to move to the Annex I-B rates.
• Annex II. Products removed from coverage.

Example of the Annex III top-up: an article with a 3.1% general rate gets an extra 11.9% so the total is 15%. An article at 2% gets 13%. An article at 16% gets nothing extra. The point is that, for these goods, the total duty from the base rate and 232 combined is fixed at 15% for most countries.

Reduced rates by origin

• United Kingdom: 25% instead of 50% for Annex I-A, or 15% for Annex I-B, where the metal was melted or smelted in the UK (CBP's guidance uses a 95% UK metal test).
• U.S. metal: 10% for articles made from metal melted or smelted in the U.S. Proclamation 11032 lowered the threshold from 95% to 85% U.S. metal.
• Derivative steel from certain partners: a 15% total rate under 9903.82.22 for Argentina, Ecuador, El Salvador, Guatemala, Japan, South Korea, Liechtenstein, Switzerland, Taiwan, the UK and EU member states, effective June 8, 2026 through December 31, 2027.
• USMCA goods from Canada and Mexico: 25% on the non-U.S. content only, with U.S. content capped at 40% of value and a 15% minimum effective duty.
• Russia: aluminum from Russia remains at 200%.

How to tell if your product is covered

1. Get the correct 10-digit HTS code. The annexes list codes at 8 or 10 digits. A wrong base code means a wrong 232 answer. Start with the classifier if you are unsure.
2. Check the CBP code list. CBP attaches a spreadsheet that maps every covered code to its Chapter 99 heading. The current one was published with CSMS 68855869 on June 5, 2026, which replaced the April list from CSMS 68253075. Search it for your code.
3. If your code is listed and outside chapters 72, 73, 74 and 76, weigh the metal. Under 9903.82.03, an article whose steel, aluminum or copper is under 15% of its total weight pays 0% 232 duty. You report the metal weight in kilograms as a second quantity.
4. Apply origin rules. Check whether a UK, partner-country, U.S.-metal or USMCA rate applies, and whether the Russia rules bite.
5. Record the metal origin. For steel you report the country where it was melted and poured. For aluminum and copper you report where it was smelted and cast. Ask your supplier for mill certificates before the goods ship.
6. Check for newer notices. Search CBP's CSMS archive and the Federal Register for "Section 232" plus your code. New products can be added on a rolling basis.

Copper and copper wire

Proclamation 10962 put a 50% duty on semi-finished copper products and copper-intensive derivatives from August 1, 2025. The list covers chapter 74 products such as copper bars, wire, plate, foil, tubes and fittings, plus insulated copper wire under 8544.42.10, 8544.42.20, 8544.42.90 and 8544.49.10. Copper ores, concentrates, cathodes and scrap are excluded.

Since April 6, 2026 copper follows the same full-value rule as steel and aluminum. CBP also requires the country of smelt and cast for the 8544 wire codes, starting July 30, 2026 (CSMS 69252300). Refined copper is still not tariffed as of October 2026. The 2025 proclamation asked Commerce to report by June 30, 2026 on a possible duty on refined copper from 2027. We found no published decision.

How 232 interacts with other tariffs

• Base duty from the HTS still applies, except for the Annex III goods where the 232 duty tops up to a fixed total.
• Section 301 on China still applies on top of Section 232. A Chinese steel article covered by a 301 list pays its base rate, the 301 duty and the 232 duty.
• Section 301 forced-labor tariff that took effect July 24, 2026 does not apply to articles subject to Section 232, so they do not stack.
• Antidumping and countervailing duties still apply.
• Other Chapter 99 reductions cannot be claimed to lower the 232 rate, according to CBP's April 2026 guidance.
• Drawback on 232 duties is limited to goods from trade-agreement partners.
• Goods listed under more than one metal pay only one 232 rate.

What is still open

• A Commerce request for comments published August 6, 2026 proposes adding 14 products under 20 HTS codes, mostly at 25%, including trailers, cranes, conductor cables, fire extinguishers and some brass instruments. Comments closed August 27, 2026. As of October 22, 2026 we found no final decision.
• The temporary 15% partner and Annex III rates end December 31, 2027 unless extended.
• Refined copper remains untariffed, with no published decision on the 2027 duty.
• Section 232 was not affected by the February 2026 Supreme Court ruling on IEEPA tariffs, and we found no court ruling against the 2026 metals proclamations.

Questions about a specific code can go to CBP at TradeRemedy@cbp.dhs.gov. For pricing, run each listed SKU through a landed cost calculation that includes the 232 rate on full value, then compare suppliers by the country where the metal was melted, not only where the product was assembled.