Section 232 in 2026: 50% Rule, US Steel Exemption, and the 95% Content Threshold

What changed for Section 232 on April 2, 2026?

The April 2, 2026 Presidential Proclamation restructured Section 232 tariffs on steel, aluminum, and copper into a tiered rate structure effective April 6, 2026. The new structure: 50% on articles made entirely or almost entirely of steel/aluminum/copper, 25% on derivative articles (those containing more than 15% metal content), 15% transitional rate on metal-intensive industrial equipment and electrical grid components through December 31, 2027, and 10% reduced rate on products made abroad using at least 95% U.S.-origin metal that meets melted-and-poured (steel) or smelted-and-cast (aluminum/copper) standards. Products with 15% or less total metal content are no longer subject to Section 232 metals tariffs. Duty is now assessed on full customs value rather than metal content value alone. The U.K. maintains a separate 25% bilateral rate.

What is the 95% U.S.-origin metal threshold?

The 95% U.S.-origin metal threshold qualifies a foreign-finished product for the 10% reduced Section 232 rate. To qualify, at least 95% of the metal used in the product must be U.S.-origin and must meet the strict "melted and poured" standard for steel or the "smelted and cast" standard for aluminum and copper. The threshold is a material U.S. content requirement that lets importers bring foreign-finished products back into the U.S. at a lower Section 232 rate if the underlying metal originated in U.S. steel mills or smelters. The qualification requires documentation showing the metal supply chain, including mill certifications or smelter certifications.

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TL;DR: Section 232 in 2026 looks very different from Section 232 in early 2025. The April 2, 2026 Presidential Proclamation restructured the tariff into a four-tier structure (50% / 25% / 15% / 10%) effective April 6, 2026, with the rate determined by how much of the article is metal and what country the metal originated in. Products with 15% or less metal content are exempt. Products made abroad using at least 95% U.S.-origin metal qualify for the reduced 10% rate. The U.K. maintains a separate 25% bilateral rate established in mid-2025. Copper was added to Section 232 in August 2025 under Proclamation 10962. The duty is now assessed on full customs value rather than the metal content value alone, which materially changes the duty math for derivative articles. Section 232 has also expanded to semiconductors (January 2026) and pharmaceuticals (April 2026), with the metals rules being only one piece of the broader Section 232 regime. GingerControl's HS classification API reaches 96% accuracy at the 6-digit level on production traffic, returns the full US tariff stack (MFN + Section 301 + Section 232 + Section 122 + Chapter 99), and accepts steel_pour_country and aluminum_pour_country fields for accurate country-of-melt tariff calculation. CBP collected $225.8 billion in duties, taxes, and fees in FY 2025, with Section 232 metals tariffs contributing materially to the year-over-year increase.

Last updated: May 2026

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The Four-Tier Section 232 Structure (Effective April 6, 2026)

The April 2, 2026 Proclamation set the rate structure based on two factors: the proportion of metal content in the article and the country of origin of the metal. The tiers:

Tier	Rate	Applies to
Top tier	50%	Articles made entirely or almost entirely of steel, aluminum, or copper (the metal IS the article)
Derivative tier	25%	Derivative articles substantially made of metal (>15% metal content)
Transitional tier	15%	Metal-intensive industrial equipment and electrical grid components (through December 31, 2027)
U.S.-origin reduced tier	10%	Products made abroad using at least 95% U.S.-origin metal meeting melted-and-poured (steel) or smelted-and-cast (aluminum/copper) standards
Exempt	0% Section 232	Products with 15% or less total metal content

Two critical changes from the pre-April 2026 framework:

1. Duty assessed on full customs value. Previously, Section 232 derivative duties were sometimes assessed on the metal content value alone. Under the new structure, the duty is assessed on the full customs value of the article, which increases the absolute duty amount on derivative articles even at the lower 25% rate.

2. Content threshold creates an exemption. Products with 15% or less metal content fall outside Section 232 entirely. This is a meaningful exemption for low-metal-content derivative articles (e.g., plastic products with metal fasteners, electronics with metal housings under the threshold).

The 95% U.S.-Origin Metal Threshold Explained

The 10% reduced Section 232 rate is available for foreign-finished products that use at least 95% U.S.-origin metal. The qualification requirements:

For steel: The metal must be melted and poured in the United States. "Melted and poured" is the standard that traces steel to the originating mill. A finished article made abroad from steel that was melted in a U.S. mill, then exported as semi-finished and finished abroad, can qualify if 95%+ of the steel content is U.S.-melted-and-poured.

For aluminum: The metal must be smelted and cast in the United States. "Smelted and cast" is the equivalent traceability standard for aluminum.

For copper: The metal must be smelted and cast in the United States. Same standard as aluminum.

Documentation: Qualification requires documentation supporting the U.S.-origin metal content claim. Mill certifications (steel) or smelter certifications (aluminum/copper) tracing the metal to U.S. origin are the typical supporting documents. The threshold is content-by-weight, with the 95%+ measurement applied to the total metal content of the finished article.

This threshold is what some industry references call the "US Steel exemption" or "US Steel test," referring to U.S.-origin steel (and by extension U.S.-origin aluminum or copper). It is distinct from any company-specific arrangement.

Country Exemptions: The U.K. Bilateral 25% Rate

When the global Section 232 rate was raised to 50% in June 2025, the United Kingdom retained a 25% rate under a bilateral arrangement. The U.K. exemption is country-specific (applies to U.K.-origin metal) and rate-specific (25% rather than 50%).

All other countries face the full 50% Section 232 rate on steel, aluminum, and copper articles in the top tier, subject to the tiered structure introduced April 2, 2026. The U.K. country-of-origin rate continues to apply alongside the new tier structure.

What Counts as "Metal Content" for the 15% Threshold

The 15% metal content threshold determines whether the article falls into the derivative tier (25%) or is exempt entirely (0%). The measurement is by weight, with metal weight as a percentage of total article weight.

Examples:

• A plastic housing with a metal screw: typically well under 15% metal by weight; exempt
• A consumer electronics device with a metal frame and internal components: typically 20-40% metal; derivative tier 25%
• An automotive bracket with a metal body and small plastic elements: typically 80%+ metal; top tier 50% (if entirely or almost entirely metal) or 25% (if derivative with some non-metal content)
• A pure steel fastener: 100% metal; top tier 50%

The classification of an article into "top tier" vs. "derivative" depends on whether the article is "entirely or almost entirely of" the relevant metal. CBP guidance and Customs rulings have provided some interpretation, but the line between "almost entirely of" and "derivative" can be product-specific.

How GingerControl's API Handles the New Section 232 Structure

The OpenAPI returns Section 232 entries in the tariff stack based on the HTSUS line classification and country-of-melt data. The API supports:

Country-of-melt fields. The request body accepts optional steel_pour_country and aluminum_pour_country fields in the extra object, both following ISO 3166-1 alpha-2 format. The Section 232 entries in the response reflect the country-of-melt determination.

{
  "description": "Steel structural bracket, machined",
  "country_of_origin": "VN",
  "extra": {
    "steel_pour_country": "US"
  }
}

For an article finished in Vietnam from U.S.-melted-and-poured steel, the API returns the Section 232 entries reflecting U.S.-origin metal content (potentially qualifying for the 10% reduced rate if 95%+ U.S.-origin content can be documented).

Full tariff stack output. The API returns MFN + Section 301 (if China-origin or other applicable list) + Section 232 (per tier) + Section 122 + Chapter 99 in a single response. The Section 232 rate reflects the tiered structure introduced April 2, 2026.

Reasoning chain. The reasoning chain in the response documents which Section 232 tier was applied and why, supporting both classification verification and audit defense.

Section 232 Beyond Metals: Semiconductors and Pharmaceuticals

The April 2, 2026 metals restructuring is one piece of a broader Section 232 expansion. Two additional categories now fall under Section 232:

Semiconductors (January 2026). Section 232 was extended to cover semiconductors at 25%. The coverage targets specific semiconductor categories and downstream products incorporating semiconductors.

Pharmaceuticals (April 2026). Section 232 was extended to cover pharmaceuticals at rates up to 100%. The pharmaceutical Section 232 framework is distinct from the metals framework and has its own product-specific rate structure.

Importers in semiconductor and pharmaceutical supply chains need to account for Section 232 alongside Section 301 (for Chinese-origin pharmaceutical APIs and electronics) and the broader tariff stack.

How the New Structure Affects Common Article Categories

Article category	Pre-April 2026	Post-April 6, 2026	Practical effect
Pure steel bar (Chapter 72)	50% (June 2025)	50% top tier	Same
Steel structural component (mostly steel, Chapter 73)	50%	50% top tier (if entirely or almost entirely steel)	Same
Steel-housing electronics (~30% metal)	50% on derivative under earlier rules	25% derivative tier	Lower rate
Plastic product with small metal screws (~5% metal)	Section 232 applied to derivative	Exempt (under 15% threshold)	Section 232 eliminated
Vietnam-finished article, U.S.-melted steel (~98% U.S. content)	50% under earlier rules	10% reduced rate (if 95%+ documented)	Materially lower rate
U.K.-origin steel article	25% bilateral	25% bilateral (within tier structure)	Same
Industrial equipment (>15% metal)	50% on derivative	15% transitional (through Dec 31, 2027)	Lower rate during transition

For importers, the new structure creates both savings opportunities (lower rates for U.S.-content products, exemption for low-metal-content products, transitional rates for industrial equipment) and complexity (documentation requirements for U.S.-content qualification, derivative-vs-top-tier determination, content threshold measurement).

Documentation Requirements for the 95% U.S.-Origin Threshold

Qualifying for the 10% reduced rate requires documentation supporting the 95%+ U.S.-origin metal content. Common documentation:

Steel: Mill test certificates (MTRs) from U.S. steel mills tracing the steel to the originating mill. Multi-source steel content requires aggregated certifications showing U.S.-origin proportion.

Aluminum: Smelter certifications tracing the aluminum to U.S. smelters. Aluminum recycling adds complexity; primary aluminum (smelted from bauxite) and recycled aluminum (re-melted) have different traceability.

Copper: Smelter certifications tracing copper to U.S. smelters. Similar to aluminum, primary and recycled copper have different traceability profiles.

Aggregation: For products made from multiple metal sources, the documentation aggregates the U.S.-origin proportion to meet the 95% threshold across the total metal content.

Documentation is the qualification gate. Without supporting documentation, the 10% reduced rate is not available even if the underlying metal supply chain would qualify.

Frequently Asked Questions

When did the new Section 232 tiered structure take effect?

The April 2, 2026 Presidential Proclamation restructured Section 232 tariffs into the four-tier structure effective April 6, 2026.

What is the 95% U.S.-origin metal threshold?

The 95% U.S.-origin metal threshold qualifies foreign-finished products for the 10% reduced Section 232 rate. To qualify, at least 95% of the metal used in the article must be U.S.-origin and must meet the "melted and poured" standard (steel) or "smelted and cast" standard (aluminum and copper). Documentation tracing the metal to U.S. mills or smelters is required.

Does the new structure apply to the U.K.?

The U.K. maintains a separate 25% bilateral rate established in June 2025. The U.K. rate continues to apply alongside the new tier structure introduced April 2, 2026.

What products are exempt under the 15% metal content threshold?

Products with 15% or less total metal content (by weight) fall outside Section 232 entirely. Examples include plastic products with small metal fasteners, electronics housings with low metal content, and other articles where metal is a minor component.

Does Section 232 apply to copper?

Yes. Copper was added to Section 232 in August 2025 under Proclamation 10962. The April 2, 2026 tiered structure applies to copper alongside steel and aluminum.

How does the API handle country-of-melt for the new structure?

GingerControl's HS classification API accepts steel_pour_country and aluminum_pour_country fields in the request body. The Section 232 entries in the response reflect the country-of-melt determination. For products with U.S.-melted steel or U.S.-smelted aluminum/copper meeting the 95% threshold, the response can reflect the 10% reduced rate eligibility (documentation required for actual qualification at filing).

Does Section 232 stack with Section 301 and Section 122?

Yes. Section 232, Section 301 (for Chinese-origin products), Section 122 (reciprocal), and Chapter 99 overlays all stack on the same entry. The total layered duty rate can exceed 100% on certain Chinese-origin metals products. The API returns all applicable layers in the response tariff stack.

How does GingerControl support Section 232 documentation for the 95% threshold?

GingerControl's compliance audit service supports documentation work including mill certification review, smelter certification aggregation, and U.S.-origin content calculation. The HS classification API supports the classification and tariff stack output; documentation work runs alongside.

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Get Your Section 232 Tariff Stack Right

If you import steel, aluminum, or copper articles, the April 2, 2026 tiered structure changed the rate determination for most of your catalog. The 50% / 25% / 15% / 10% / exempt tiers apply based on metal content proportion and country of metal origin. Getting the tier wrong creates either overpayment or underpayment exposure.

Try the GingerControl API at gingercontrol.com/products/openapi. The OpenAPI is faster, cheaper, and more accurate than the alternatives, and has already saved customers a combined $4M in duties through optimized HTS classification and full tariff stack visibility. You can test the live API speed and see real response times directly on the page.

GingerControl is not just a tool. Our team includes native Mandarin, Cantonese, Spanish, and English speakers who support Section 232 strategy across steel, aluminum, and copper supply chains. Talk to our team about getting your Section 232 tariff stack right under the April 2 2026 tiered structure.

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References

[REF 1] U.S. Customs and Border Protection, Section 232 Aluminum and Steel Tariffs Data cited: Section 232 rate framework, country-of-melt rules, derivative article coverage Source: CBP Section 232

[REF 2] U.S. Customs and Border Protection, Section 232 Tariffs FAQs Data cited: Section 232 implementation details Source: CBP Section 232 FAQs

[REF 3] Perkins Coie, Restructured and Additional Section 232 Tariffs on Aluminum, Steel, and Copper Data cited: April 2, 2026 tiered structure analysis Source: Perkins Coie Section 232 Update Published: April 2026

[REF 4] Congressional Research Service, Section 232 Tariffs on Steel and Aluminum Data cited: Legislative and regulatory framework Source: CRS Section 232

[REF 5] Global Trade & Sanctions Law, Trump Administration Section 232 Metal Duties Data cited: April 6, 2026 restructuring legal analysis Source: Global Trade & Sanctions Law Published: April 6, 2026

[REF 6] U.S. Customs and Border Protection, Trade Statistics Data cited: $225.8 billion in duties, taxes, and fees collected in FY 2025 Source: CBP Trade Statistics Published: 2025

[REF 7] Proclamation 10962, Adding Copper to Section 232 (August 2025) Data cited: Copper coverage addition to Section 232 framework Source: White House Proclamation 10962 Published: August 2025