Section 232 in 2026: 50% Rule, US Steel Exemption, and the 85% 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 Annex I-A articles (most goods of Chapters 72, 73 and 76, such as nails, fasteners and aluminum profiles), 25% on Annex I-B derivative articles, a combined 15% (MFN plus Section 232) on Annex III fixed industrial machinery and power equipment through December 31, 2027, and 10% reduced rate on products made abroad using U.S.-origin metal that meets melted-and-poured (steel) or smelted-and-cast (aluminum/copper) standards: at least 95% of the metal at first, and at least 85% by weight since June 8, 2026 (Proclamation 11032). For listed articles outside Chapters 72, 73, 74 and 76, the metal duties apply only where the metal is at least 15% of the article's weight. Duty is now assessed on full customs value rather than metal content value alone. U.K. steel and aluminum articles pay 25% in Annex I-A and 15% in Annex I-B when at least 95% of their steel was melted and poured, or their aluminum smelted or most recently cast, in the U.K. (U.S. note 16(d)).

For a data-center project, AI data-center power and cooling import duty follows the power and cooling equipment rather than assuming the chips drive the whole duty bill.

What is the 85% U.S.-origin metal threshold?

The 85% U.S.-origin metal threshold qualifies a foreign-finished product for the 10% reduced Section 232 rate. To qualify, since June 8, 2026 at least 85% of the content of each listed metal in the product must be U.S.-origin by weight (from April 6 to June 7, 2026 the threshold was 95%), and the metal 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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The Four-Tier Section 232 Structure (Effective April 6, 2026)

The April 2, 2026 Proclamation set the rate structure based on two factors: the annex the article's HTS code is listed in and the country where its metal was melted or smelted. The tiers:

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. A weight floor for listed articles outside the metal chapters. For listed articles outside Chapters 72, 73, 74 and 76, the metal duties apply only where the metal is at least 15% of the article's weight (U.S. note 16(c)); lighter articles pay no metal duty. This matters for low-metal-content derivative articles (e.g., plastic products with metal fasteners, electronics with light metal parts).

The 85% U.S.-Origin Metal Threshold Explained

The 10% reduced Section 232 rate is available for foreign-finished products where at least 85% of the content of each listed metal is U.S.-origin by weight (U.S. note 16(e)), the threshold Proclamation 11032 set from June 8, 2026; from April 6 to June 7, 2026 it was 95%. 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 85%+ of the steel content by weight 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 85%+ measurement applied to the content of each listed metal in the finished article (U.S. note 16(e)).

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. Rates

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. Under that structure, U.K. steel and aluminum articles pay 25% in Annex I-A and 15% in Annex I-B when at least 95% of their steel was melted and poured, or their aluminum smelted or most recently cast, in the U.K. (U.S. note 16(d)); other U.K. goods pay the general rates.

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

The 15% threshold applies only to listed articles outside Chapters 72, 73, 74 and 76: below it, the metal duty does not apply; at or above it, the article pays the rate of the annex its HTS code is listed in. The measurement is by weight, with metal weight as a percentage of total article weight.

Examples:

• A listed plastic housing with a metal screw: typically well under 15% metal by weight; no metal duty
• A listed consumer electronics device with a metal frame and internal components, typically 20-40% metal: 25% if its HTS code is in Annex I-B
• A steel fastener (heading 7318): Annex I-A, 50%, with no weight test because it is in Chapter 73

Whether an article pays 50% or 25% depends on the annex its HTS code is listed in, so the classification decides the rate; vehicle parts are covered by the separate Section 232 auto parts duty instead.

For heavy vehicles and their covered parts, check the Section 232 heavy vehicle tariff separately from passenger-car treatment.

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 85%+ 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) + other Chapter 99 lines in force on the day of the call, in a single response. The Section 232 rate reflects the tiered structure introduced April 2, 2026.

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.

Check the Section 232 semiconductor tariff and exemptions before assuming that every chip or electronics import receives the same surcharge.

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

For importers, the new structure creates both savings opportunities (lower rates for U.S.-content products, no metal duty for light listed articles, transitional rates for industrial equipment) and complexity (documentation requirements for U.S.-content qualification, the annex each HTS code sits in, content threshold measurement).

Documentation Requirements for the 85% U.S.-Origin Threshold

Qualifying for the 10% reduced rate requires documentation supporting the 85%+ 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.

Each listed metal on its own: The HTSUS applies the 85% test to the metal named by the list the article is on: for a steel derivative, at least 85% of its steel content must be U.S. melted and poured; for an aluminum derivative, at least 85% of its aluminum content U.S. smelted and cast; for a copper article, at least 85% of its copper content. An article on more than one list must pass each test (U.S. note 16(e)). Proclamation 11032 words it as 85% of the combined weight, so document each metal on its own.

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 85% U.S.-origin metal threshold?

The 85% U.S.-origin metal threshold qualifies foreign-finished products for the 10% reduced Section 232 rate. To qualify, since June 8, 2026 at least 85% of the content of each listed metal in the article, by weight, must be U.S.-origin (95% from April 6 to June 7, 2026), and the metal 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. kept a 25% rate when the general rate rose to 50% in June 2025. Under the tier structure introduced April 2, 2026, U.K. steel and aluminum articles pay 25% in Annex I-A and 15% in Annex I-B when at least 95% of their steel was melted and poured, or their aluminum smelted or most recently cast, in the U.K. (U.S. note 16(d)); other U.K. goods pay the general rates.

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

Listed articles outside Chapters 72, 73, 74 and 76 pay no metal duty when their metal is less than 15% of their weight (U.S. note 16(c)). Examples include plastic products with small metal fasteners, electronics housings with low metal content, and other articles where metal is a minor component. Goods of Chapters 72, 73, 74 and 76 have no such floor.

For a complete electronic device using one of these housings, review the Chapters 85 and 90 electronics classification questions separately from the housing’s metal-content test.

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 85% threshold, the response can reflect the 10% reduced rate eligibility (documentation required for actual qualification at filing).

Does Section 232 stack with Section 301?

Yes. Section 232 and China's Section 301 list duties stack on the same entry, and the total layered duty rate can exceed 100% on certain Chinese-origin metals products. Section 232 articles are exempt from the forced-labor Section 301 (9903.05.90), and the Section 122 surcharge that applied from February 24 to July 23, 2026 did not stack on Section 232 duties. The API returns all applicable layers in the response tariff stack.

How does GingerControl support Section 232 documentation for the 85% threshold?

GingerControl's Trade Advisory service, quoted for its scope, gives a second pair of eyes on the tariff questions behind the 85% threshold. 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% tiers and the 15% weight floor apply based on the annex each HTS code is listed in and where the metal was melted or smelted. Getting the tier wrong creates either overpayment or underpayment exposure.

See the GingerControl API at gingercontrol.com/products/openapi. It is for enterprise systems, starts with a call and has no published price.

Our trade advisory service, quoted for its scope, reviews Section 232 questions on steel, aluminum and copper goods as a second pair of eyes. Book a call about getting your Section 232 tariff stack right under the April 2 2026 tiered structure.

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References

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
2. U.S. Customs and Border Protection, Section 232 Tariffs FAQs
   Data cited: Section 232 implementation details
   Source: CBP Section 232 FAQs
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
4. Congressional Research Service, Section 232 Tariffs on Steel and Aluminum
   Data cited: Legislative and regulatory framework
   Source: CRS Section 232
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
6. U.S. Customs and Border Protection, Trade Statistics
   Data cited: $216.7 billion in duties, taxes, and fees collected in FY 2025
   Source: CBP Trade Statistics
   Published: 2025
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
8. Proclamation 11032, Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States (91 FR 34085)
   Data cited: from June 8, 2026, the U.S.-metal threshold is 85% (clause 4), down from 95%; HTSUS U.S. note 16(e) applies it to the content of each listed metal
   Source: Federal Register 2026-11314
   Published: June 4, 2026

Related industries

For the full 2026 duty stack, recovery levers, and FAQs for this sector, see the Metals: Steel, Aluminum & Copper industry guide.