New Section 232 proclamation restructures and raises tariffs on many steel, aluminum, and copper imports, with flat 50%, 25%, 15%, and 10% rates by product type.

FACT SHEET REGULATORY BRIEFING

President Trump Proclamation Strengthening Section 232 Tariffs on Steel, Aluminum, and Copper Imports

1. What changed

• A new Presidential Proclamation (April 2, 2026) modifies the structure and application of Section 232 tariffs on imports of steel, aluminum, and copper and their derivatives.
• The Proclamation:
• Redefines how tariffs are assessed so they apply to the full customs value of covered products, not a reduced or “artificially low” foreign price.
• Establishes flat ad valorem tariff rates based on the degree of steel/aluminum/copper content and product type.
• Introduces differentiated rates for:
• Articles made entirely or almost entirely of steel, aluminum, or copper.
• Derivative articles substantially made of these metals.
• Certain metal‑intensive industrial and electrical grid equipment.
• Products made abroad using 100% U.S.-origin steel, aluminum, and copper.
• Products with low metal content (≤15%), which are now exempt from Section 232 metals tariffs.
• The Proclamation builds on prior actions:
• February 2025: Elimination of many product- and country-specific exclusions and exemptions.
• June 2025: Increase of steel and aluminum Section 232 tariffs to 50%.
• July 2025: Addition of copper to Section 232 at a 50% rate.

2. Affected products

2.1 Product scope (general)

The Proclamation affects:

• Steel products and articles made of steel.
• Aluminum products and articles made of aluminum.
• Copper products and articles made of copper.
• Derivative articles that are substantially made of steel, aluminum, or copper.
• Certain metal-intensive industrial equipment and electrical grid equipment.

While the Fact Sheet does not list specific HTS codes, the affected universe will generally align with:

• Steel: HTS Chapter 72 (iron and steel) and Chapter 73 (articles of iron or steel), plus derivative products in other chapters where steel is the primary material.
• Aluminum: HTS heading 7601–7616 and derivative products in other chapters where aluminum is the primary material.
• Copper: HTS heading 7401–7419 and derivative products in other chapters where copper is the primary material.

Examples (illustrative only – importers must confirm exact HTS and coverage under the Proclamation and implementing notices):

• Articles made entirely or almost entirely of steel/aluminum/copper (50% rate):
• Steel coils, plate, sheet, strip (e.g., 7208, 7209, 7211, 7212).
• Aluminum sheet, plate, foil, extrusions (e.g., 7606, 7607, 7604).
• Copper cathodes, bars, rods, profiles, wire (e.g., 7403, 7407, 7408).
• Derivative articles substantially made of these metals (25% rate):
• Fasteners, fittings, flanges, and hardware where steel/aluminum/copper is the main material.
• Fabricated structural components, frames, and assemblies.
• Metal-intensive consumer goods where the primary material is one of the three metals.
• Certain metal-intensive industrial and electrical grid equipment (15% rate through 2027):
• Heavy industrial machinery with high steel/aluminum/copper content.
• Transformers, substations, and grid infrastructure equipment.
• Large-scale process equipment for manufacturing and energy sectors.
• Products made abroad entirely with U.S.-origin steel, aluminum, and copper (10% rate):
• Components or assemblies manufactured overseas using 100% U.S.-produced steel/aluminum/copper inputs.
• Products with ≤15% steel, aluminum, or copper content (0% Section 232 rate):
• Goods where the combined weight or value of steel/aluminum/copper is 15% or less of the total product.

3. Rate changes and structure

3.1 New Section 232 tariff structure

The Proclamation establishes the following flat ad valorem rates on the full customs value of the imported article:

• 50% rate:
• Applies to articles made entirely or almost entirely of steel, aluminum, or copper.
• Example: Steel coils and aluminum sheet are explicitly cited as 50% items.
• 25% rate:
• Applies to derivative articles substantially made of steel, aluminum, or copper.
• 15% rate (time-limited):
• Applies to certain metal-intensive industrial equipment and electrical grid equipment.
• Valid “through 2027” (exact end date to be confirmed in the Proclamation/implementing notices).
• 10% rate:
• Applies to products made abroad but entirely with American steel, aluminum, and copper.
• 0% Section 232 rate (exempt):
• Products made of 15% or less steel, aluminum, or copper are no longer subject to Section 232 metals tariffs.

3.2 Comparison to prior rates

• Prior to this Proclamation:
• Steel and aluminum Section 232 tariffs had been increased to 50% in June 2025.
• Copper was added to Section 232 at 50% in July 2025.
• The new structure:
• Maintains a 50% rate for core metal products (entirely or almost entirely metal).
• Introduces lower rates (25%, 15%, 10%) for certain derivative or special-category products.
• Eliminates Section 232 tariffs for low-metal-content products (≤15%).

4. Dates and timing

• Proclamation date: April 2, 2026.
• Effective date: The Fact Sheet does not specify the exact effective date; importers must confirm in the official Proclamation and any CBP/Commerce implementation guidance. Typically, such changes take effect on a specified future date (e.g., within days or weeks of signing).
• Duration of special 15% rate:
• Applies “through 2027” for certain metal-intensive industrial and electrical grid equipment.
• Importers should monitor for a precise sunset date (e.g., December 31, 2027) in the Proclamation or subsequent Federal Register notices.

5. Required actions for importers, brokers, and compliance teams

5.1 Reassess product coverage and classification

• Review all imported products containing steel, aluminum, or copper to determine:
• Whether they are “entirely or almost entirely” made of these metals (likely 50% rate).
• Whether they are “derivative articles substantially made” of these metals (25% rate).
• Whether they qualify as “certain metal-intensive industrial equipment and electrical grid equipment” (15% rate through 2027).
• Whether they are made abroad entirely from U.S.-origin steel/aluminum/copper (10% rate).
• Whether the combined steel/aluminum/copper content is 15% or less (0% Section 232 rate).
• Confirm HTS classification for each product and identify any applicable Chapter 99 Section 232 provisions once CBP publishes implementing instructions.

5.2 Determine metal content thresholds

• Establish internal methodologies to determine whether a product:
• Exceeds or falls below the 15% metal-content threshold.
• Qualifies as “entirely or almost entirely” or “substantially” made of steel/aluminum/copper.
• Recommended steps:
• Obtain detailed bills of materials (BOMs) and material composition data from suppliers.
• Quantify metal content by weight and/or value, depending on how CBP/Commerce define the thresholds in implementing guidance.
• Maintain documentation (technical specs, BOMs, supplier declarations) to support the chosen rate category in case of CBP review.

5.3 Verify origin of metal inputs for 10% rate

• For products potentially eligible for the 10% rate (made abroad entirely with American steel, aluminum, and copper):
• Obtain robust supplier certifications confirming that 100% of the steel/aluminum/copper content is U.S.-origin.
• Maintain traceability documentation (mill test certificates, purchase records, origin statements) linking the finished product to U.S.-origin metal inputs.
• Implement controls to prevent commingling of U.S.-origin and non-U.S.-origin metals in production streams.

5.4 Update customs entry processes

• Coordinate with customs brokers to:
• Apply the correct Section 232 rate category at time of entry.
• Use the appropriate Chapter 99 numbers and any new special program indicators once published by CBP.
• Ensure that the dutiable value used for Section 232 is the full customs value of the article, consistent with the Proclamation’s requirement.
• Update internal systems (ERP, trade compliance software) to:
• Reflect new duty rates (50%, 25%, 15%, 10%, or 0% Section 232) by SKU/HTS.
• Flag products near the 15% metal-content threshold for additional review.

5.5 Pricing, contracts, and supply chain planning

• Recalculate landed cost impacts for all affected imports:
• Identify SKUs moving from 50% to lower rates (25%, 15%, 10%) or to 0% due to low metal content.
• Identify SKUs that may newly fall under 50% or 25% due to redefinition of coverage.
• Review and, where possible, renegotiate contracts with customers and suppliers to address:
• Pass-through of increased or decreased tariff costs.
• Sourcing shifts to reduce exposure (e.g., using U.S.-origin metals to qualify for 10% rate, or redesigning products to reduce metal content below 15%).
• Evaluate reshoring or nearshoring options in light of the strengthened Section 232 regime and potential incentives for domestic production.

5.6 Compliance documentation and audit readiness

• Prepare for heightened CBP scrutiny on:
• Metal content calculations and threshold determinations.
• Claims of U.S.-origin metal inputs for the 10% rate.
• Classification of products as “industrial equipment” or “electrical grid equipment” for the 15% rate.
• Maintain a central file for each product family including:
• HTS classification rationale.
• Metal content analysis and supporting data.
• Origin documentation for metal inputs.
• Legal and technical interpretations used to assign the applicable Section 232 rate.

5.7 Monitor for implementing guidance

• Closely monitor:
• Federal Register for the full text of the Proclamation and any implementing regulations.
• U.S. Customs and Border Protection (CBP) Cargo Systems Messaging Service (CSMS) for operational instructions and Chapter 99 code updates.
• Department of Commerce and USTR communications for clarifications on definitions (e.g., “almost entirely,” “substantially,” “metal-intensive industrial equipment”).

6. Key risk and opportunity areas

• Risk areas:
• Misclassification of products into lower-rate categories (25%, 15%, 10%, or exempt) without sufficient support.
• Underestimation of metal content leading to incorrect claims of ≤15% and 0% Section 232.
• Inadequate documentation of U.S.-origin metal inputs.
• Opportunity areas:
• Re-engineering products to reduce steel/aluminum/copper content below 15% where feasible.
• Shifting to U.S.-origin metal inputs to qualify for the 10% rate on foreign-assembled goods.
• Leveraging the 15% rate for qualifying industrial and grid equipment through 2027.

7. References and where to find more information

(Note: URLs are indicative; importers should verify final links once published.)

• White House Fact Sheet (April 2, 2026):
• https://www.whitehouse.gov/briefing-room/statements-releases/2026/04/02/fact-sheet-president-donald-j-trump-strengthens-tariffs-on-steel-aluminum-and-copper-imports/
• Presidential Proclamation on Adjusting Imports of Steel, Aluminum, and Copper (Section 232):
• Likely published at: https://www.whitehouse.gov/presidential-actions/ (search by date and title)
• Federal Register publication of the Proclamation and implementing details:
• https://www.federalregister.gov
• CBP Cargo Systems Messaging Service (CSMS) for operational guidance and Chapter 99 codes:
• https://www.cbp.gov/trade/automated/cargo-systems-messaging-service

Importers should not rely solely on the Fact Sheet; they must review the official Proclamation, Federal Register notices, and CBP guidance to confirm exact HTS coverage, effective dates, and operational requirements before making entry decisions.