Section 232 tariffs started in 2018 as a national security measure on steel and aluminum, at 25 percent and 10 percent. The April 2, 2026 proclamation, Proclamation 11021, rewrote the structure. Primary steel, aluminum, and copper now carry 50 percent. Derivatives, products made from those metals, carry 25 percent. The United Kingdom gets 25 percent on primary metals under its trade deal. Russian aluminum still carries 200 percent. And de minimis, the exemption for low-value shipments, has been suspended for all countries since August 29, 2025, so there is no low-value escape hatch left.
The change that catches importers is not the rate. It is the base. The 50 percent and 25 percent rates apply to the full customs value of the product, not to the value of the metal content inside it. A product that is 20 percent steel by value and 80 percent everything else pays 50 percent on the whole product. That is the rule, and it is the rule that importers who built their models on metal content keep missing.
The entry has to split the value: the metal content and the rest, declared separately, so CBP can see the metal content percentage and apply the exemption test. Products with 15 percent or less metal content by value are exempt from the Section 232 duty entirely. The split has to be documented, and the documentation has to come from the supplier: a mill certificate, a cost breakdown, or a bill of materials that shows where the metal came from and what it is worth.
The mistakes are predictable. A supplier who cannot document the metal content leaves the importer with no basis for the exemption, and the full rate applies. A supplier who overstates the non-metal content to push the product under 15 percent leaves the importer exposed when CBP asks for the mill certificate. And a product that contains steel from a country subject to a different rate, like Russian aluminum at 200 percent, needs the origin tracked separately, because the rate follows the metal's origin, not the product's.
Model the duty on the full value, not on the metal content, and model it at the rate in effect on the entry date, not the rate in effect when the purchase order was signed. The proclamation can change the rate between order and arrival, and the entry pays the rate on the day it clears. Then model the exemption: if the product is near 15 percent metal content, get the supplier documentation now, because the exemption is worth real money and the documentation is the only thing that proves it.
If the product is a derivative, check whether the metal content is steel, aluminum, or copper, and whether the origin country changes the rate. The UK's 25 percent on primary metals is the only country-specific break in the current structure. Everything else pays the full rate, and the full rate is on the full value. For the classification side of the same problem, tariff engineering and whether it is legal covers the redesign question, and de minimis is gone explains the low-value exemption that no longer exists.
Since the April 2, 2026 proclamation, effective April 6: 50 percent on primary steel, aluminum, and copper, 25 percent on derivatives, 25 percent on primary metals from the UK, and 200 percent on Russian aluminum.
The full customs value of the product. A product that is 20 percent steel by value pays 50 percent on the whole product, not on the 20 percent that is steel.
Yes. Products with 15 percent or less metal content by value are exempt from the Section 232 duty. The exemption has to be documented with supplier evidence such as a mill certificate or cost breakdown.
No. De minimis has been suspended for all countries since August 29, 2025. There is no low-value exemption for Section 232 products.