I almost, OK not really, feel sorry for the bureaucrats that have to keep track of, and calculate the ever changing tariff pronouncements.
It would make a computer dizzy.
It goes all the way down the chain.
Dear RON, the White House issued a new proclamation on aluminum, steel and copper imports that takes effective April 6, 2026. We're providing all the details to help you prepare!
Imports into the US - New Section 232 Metals Tariff Changes
Effective April 6, 2026
On April 2, 2026, the White House issued a new Proclamation on aluminum, steel, and
copper imports, together with a related White House Fact Sheet. These changes are effective for goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 6, 2026.
The new framework provides for the following treatment of covered aluminum, steel, copper, and certain derivative articles:
• 50% Section 232 duty for products identified in Annex I-A
• 25% Section 232 duty for products identified in Annex I-B
• Removal from scope for products identified in Annex II
• Temporary special treatment through December 31, 2027, for certain steel and aluminum derivative products identified in Annex III
• Certain limited lower-rate treatment, including for specified qualifying products made with U.S.-origin metal content and for certain U.K. products
Notable Changes:
• Breakdown of Content and Non-Content Values are no longer required.
• Duty assessments based on full value of imported article
• Country of Melt and Pour for Steel – Still Required
• Country of Smelt and Cast for Aluminum – Still Required
• Country of Smelt and Cast for Copper – Now Required
Rate Structure by Category
Aluminum articles, steel articles, most copper articles, and certain Annex I-A 50% aluminum/steel derivatives. Default rate for the broadest category of covered metals from all countries not eligible for a reduced rate.
Annex I-B 25% Certain copper articles and select aluminum/steel derivative articles.
Default rate for this product list absent a qualifying reduced rate.
Products removed from Section 232 scope. Includes goods with ≤15% steel, aluminum, or copper content, where the Secretary of Commerce
Annex II – determined tariffs no longer materially address national security concerns.
Derivatives Exempt HTS codes to be confirmed via forthcoming Federal Register notice.
Removed
Note: If an article is classified in a provision that is present on multiple lists, use the aggregate weight of the listed metals.Tariff Update Advisory – April 3rd, 2026
Metal-intensive industrial and electrical grid equipment. Combined Section
Annex III – 15%
232 + Column 1 HTSUS duty rate capped at 15% through December 31,
Transitional cap 2027. Standard Annex I-B rates apply beginning January 1, 2028. Applies where aluminum was smelted or most recently cast in the UK, or UK-Origin Metal
– Annex I-A 25% steel was melted and poured in the UK. Subject to ongoing U.S.–UK trade discussions.
UK-Origin Metal
– Annex I-B 15% Same UK-origin conditions as above, applied to Annex I-B products. Applies where aluminum is entirely smelted and cast in the U.S., steel is U.S.-Origin Metal –
All Derivatives 10% entirely melted and poured in the U.S., or copper is entirely smelted and cast in the U.S. Importer documentation required for CBP.
Applies to all Russian-origin aluminum articles and any derivative
Russia – Aluminum 200% containing primary aluminum smelted or cast in Russia. Continues under Proclamation 10522 and is not reduced by April 2026 measures.
The applicable HTSUS and tariff provisions are set out in the official Annexes I-A, I-B, II, III, and IV .
Importers should immediately review affected HTS classifications, sourcing, supplier declarations, and metal-content documentation to determine whether merchandise falls within the applicable annexes and whether any reduced-rate treatment may apply. CBP’s general trade-remedy guidance is available on its Trade Remedies page. These changes are broad reaching and complex, so it is important to review this information carefully to determine the impact it may have on your products.
This alert is intended as a general summary for informational purposes only. Tariff applicability depends on product classification, origin, sourcing, and supporting documentation. Importers remain responsible for the accuracy of entry declarations and for providing sufficient records to determine tariffs, rates, and the applicability of any exclusions. Please contact us at ******* if you would like assistance reviewing impacted products, classifications, or potential duty exposure.
As this communication is not legal advice, we also recommend consultation with counsel regarding product specific applicability.