On April 2, 2026, the President issued a proclamation under Section 232 of the Trade Expansion Act of 1962, substantially revising how Section 232 tariffs apply to steel, aluminum, and copper and to finished products that combine them with non-metal materials, the so-called derivatives. The changes apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on April 6, 2026.
The most significant change is the move away from the content-based system in effect since June 2025, which applied Section 232 tariffs on derivatives measured by the precise metal content of the imports. The new process applies tariffs to the full customs value of the finished products themselves, within broad categories of metal content and specified HTSUS classifications set out in the annexes. The revised framework abandons the requirement to calculate the value of steel or aluminum content and adopts a classification-based methodology instead.
The proclamation establishes a two-tier core rate structure. A 50 percent additional duty on full customs value applies to most aluminum articles, most steel articles, and a broad range of derivative products listed in Annex I-A. A 25 percent additional duty on full customs value applies to a wide array of derivative articles, including certain copper wiring and cable, listed in Annex I-B. The changes are implemented through revised Section 232 Chapter 99 provisions, primarily heading 9903.82.02.
For derivative products, the metal content share still matters, but as a tier test rather than a valuation exercise. Derivatives in which the value of the foreign metal content is greater than 15 percent by weight pay a flat 25 percent on the entire customs value of the finished product, not solely on the metal content. Derivatives in which the non-US metal content is 15 percent or less by weight pay no Section 232 tariff at all, regular MFN and Column 1 duties only.
Foreign-manufactured imports in which the metal content is at least 95 percent US origin, melted and poured or smelted and cast in the US, pay a 10 percent flat rate on the entire finished product. Products from the United Kingdom, the European Union, Japan, and South Korea continue to receive reduced rates consistent with their existing trade agreements, and imports of aluminum articles that are products of Russia, or for which any amount of primary aluminum was smelted or cast in Russia, still carry the 200 percent rate.
The origin question reaches past final assembly, and that is the part importers keep missing. Section 232's melt-and-pour requirement for steel and smelt-and-cast requirement for aluminum look further upstream, at where the metal itself was melted and poured or smelted and cast, a step that later processing elsewhere does not reset. A finished article can be a product of Canada or Mexico under the ordinary origin rules and still contain steel melted and poured somewhere else, and the Section 232 rate follows the metal, not the assembly country.
Find your product in the annexes first. The applicable rate is determined by the product's HTS classification and the corresponding Section 232 tariff category assigned to that product, so the classification work comes before the duty math. A product that was a 25 percent content-based calculation in March 2026 may be a 50 percent full-value duty in April, and the difference is not a rounding error.
Document the melt-and-pour or smelt-and-cast country for every steel and aluminum component, and trace the metal upstream to the mill. The 2025 reset made Section 232 a product-data problem as much as a tariff problem: a covered finished article may require the importer to isolate the value and weight of every covered component and trace it to the melt. If the supplier cannot provide that documentation, the importer cannot claim the lower tier, and CBP will apply the higher one.
And check drawback and FTZ treatment before assuming the duty is final. Manufacturing drawback is allowed for items listed in Annex I-B or Annex III if the product is not subject to an antidumping or countervailing duty order, the article is a product of a trading partner with an Agreement on Reciprocal Trade, and the metal was melted and poured or smelted and cast in that country. The FTZ and drawback rules changed with the proclamation too, and the entry that ignores them overpays.
Keep reading: Tariff engineering has a legal line: where product changes become evasion, Scope rulings and EAPA cases ask different questions: do not confuse them.
Section 232 of the Trade Expansion Act of 1962 starts with an investigation by the Department of Commerce into whether a category of imports threatens to impair US national security, examining domestic production capacity, demand, employment, and the health of industries Commerce considers essential to national defense.
The original March 2018 proclamations imposed 25 percent on covered steel and 10 percent on covered aluminum. In March 2025 the rate went to 25 percent for both, and in June 2025 Proclamation 10947 increased the general steel and aluminum rate from 25 to 50 percent. The April 2026 proclamation kept the 50 percent core rate and changed how it is calculated.
Melt and pour is where the steel was melted and poured. Smelt and cast is the equivalent for aluminum and copper: where the metal was smelted and cast. These are metallurgical production steps, not synonyms for where the finished article was assembled, and CBP reporting reaches to them even when the finished article is a product of a different country.
A 10 percent flat rate applies to the entire finished product when the metal content is at least 95 percent US origin, melted and poured or smelted and cast in the United States. Products from the United Kingdom, the EU, Japan, and South Korea continue to receive reduced rates under their existing trade agreements.