New Section 232 tariffs (25–100%) on UAS and UAS components via HTSUS Ch.99 9903.08.2x effective Sept. 3, 2026 and Feb. 9, 2027.

1. What changed

A Section 232 action has been proclaimed on imports of unmanned aircraft systems (UAS) and UAS components. New additional ad valorem duties of 25% and 100% are imposed via Chapter 99 of the HTSUS, along with new U.S. note 43 and new headings 9903.08.20–9903.08.26. These duties are in addition to normal Column 1 rates and any other applicable duties (including Section 301, ADD/CVD, etc.).

Key elements:

• 100% additional duty on specified UAS (including those with thermal imaging), UAS docking stations, and certain critical components (Annex I).
• 25% additional duty on UAS ≤25 kg without thermal imaging (Annex II).
• 25% additional duty on specified UAS components when imported for use in UAS (Annex III), effective later.
• Preferential capped rates (10% or 15% total) for qualifying products from the UK, EU, Japan, Korea, Taiwan, Switzerland, Liechtenstein, subject to content certification.
• Onshoring incentive program allowing duty-free import of covered products and equipment under approved plans.
• FTZ, drawback, and Chapter 98/99 interaction rules are specified.

2. Effective dates

Primary effective dates:

• September 3, 2026, 12:01 a.m. ET
• New U.S. note 43 to Subchapter III of Chapter 99 and new headings 9903.08.20–9903.08.26 become effective.
• Additional Section 232 duties apply to UAS and components listed in Annex I and Annex II.

• February 9, 2027, 12:01 a.m. ET
• 25% additional Section 232 duty becomes effective for UAS components listed in Annex III.
• U.S. note 43 is amended to add subdivision (c)(5) (additional parts/components for use in or with UAS).
• Heading 9903.08.22 is broadened to cover parts and components under (c)(4) and (5).
• Heading 9903.08.25 is terminated and deleted from the HTSUS.

Special timing provisions:

• Companies on the Department of War (DoW) Blue UAS Cleared List, Blue UAS Framework, or FCC Conditional Approval List on September 2, 2026:
• For covered products and their components, the effective date of the new duties under clause (1) is delayed to 180 days from the date of the proclamation (i.e., February 9, 2027, unless otherwise adjusted by implementing notices).

• Additional components added later by the Secretary of Commerce:
• Effective for goods entered or withdrawn for consumption on or after 12:01 a.m. ET on the date of the Secretary’s finding (or first practicable date) as specified in a Federal Register notice.

3. Affected products and HTS codes

3.1 New Chapter 99 structure (Annex IV)

New U.S. note 43 to Subchapter III of Chapter 99:

• Defines scope of headings 9903.08.20–9903.08.26 and links them to specific 8- and 10-digit HTSUS numbers.
• Confirms these headings are mutually exclusive (only one applies per entry line).

New Chapter 99 headings:

• 9903.08.20 – Articles provided for in the enumerated provisions of U.S. note 43(c) that are not for use in or with the products described therein.
• 9903.08.21 – UAS, their parts and components as per U.S. note 43(c)(1)–(3), except where 9903.08.23–.26 apply.
• 9903.08.22 – UAS and, after amendment, their parts and components as per U.S. note 43(c)(4) and (5), except where 9903.08.23–.26 apply.
• 9903.08.23 – UAS, parts and components that are products of the United Kingdom, meeting content criteria.
• 9903.08.24 – UAS, parts and components that are products of Japan, Liechtenstein, South Korea, Switzerland, Taiwan, or EU member states, meeting content criteria.
• 9903.08.25 – UAS, parts and components imported for companies subject to an onshoring plan approved by DHS or DoW (deleted effective February 9, 2027).
• 9903.08.26 – UAS, parts and components imported subject to an onshoring plan approved by the Secretary of Commerce.

3.2 Base HTSUS numbers covered (U.S. note 43(c) and Annexes)

U.S. note 43(c) identifies the following base HTSUS numbers as subject to the new Chapter 99 headings when used in or as UAS:

(1) Unmanned aircraft, docking stations for unmanned aircraft, or parts for such docking stations:

• 8504.40.9580 – Static converters, other, for use in UAS (Annex I).
• 8537.10.9170 – Certain electrical control/distribution boards, panels, etc., for use in UAS (Annex I).
• 8806.24.00 – UAS, remote-controlled, >25 kg but ≤150 kg (Annex I).
• 8806.29.00 – UAS, remote-controlled, >150 kg (Annex I).
• 8806.94.00 – UAS, non-remote-controlled, >25 kg but ≤150 kg (Annex I).
• 8806.99.00 – UAS, non-remote-controlled, >150 kg (Annex I).

(2) Parts or components for use in or with a UAS with maximum take-off weight >25 kg (except for retail delivery, agricultural use, or sale to DoW):

• 8807.10.00 – Propellers and rotors and parts thereof.
• 8807.20.00 – Undercarriages and parts thereof.
• 8807.30.00 – Other parts of airplanes or helicopters.
• 8807.90.90 – Other parts, nesoi.

(3) Unmanned aircraft with thermal imaging (TI):

• 8806.21.00 – UAS, remote-controlled, ≤250 g (TI scope in Annex I).
• 8806.22.00 – UAS, remote-controlled, >250 g but ≤7 kg (TI scope in Annex I).
• 8806.23.00 – UAS, remote-controlled, >7 kg but ≤25 kg (TI scope in Annex I).
• 8806.91.00 – UAS, non-remote-controlled, ≤250 g (TI scope in Annex I).
• 8806.92.00 – UAS, non-remote-controlled, >250 g but ≤7 kg (TI scope in Annex I).
• 8806.93.00 – UAS, non-remote-controlled, >7 kg but ≤25 kg (TI scope in Annex I).

(4) Unmanned aircraft without thermal imaging:

• 8806.21.00 – UAS, remote-controlled, ≤250 g (non-TI scope in Annex II).
• 8806.22.00 – UAS, remote-controlled, >250 g but ≤7 kg (non-TI scope in Annex II).
• 8806.23.00 – UAS, remote-controlled, >7 kg but ≤25 kg (non-TI scope in Annex II).
• 8806.91.00 – UAS, non-remote-controlled, ≤250 g (non-TI scope in Annex II).
• 8806.92.00 – UAS, non-remote-controlled, >250 g but ≤7 kg (non-TI scope in Annex II).
• 8806.93.00 – UAS, non-remote-controlled, >7 kg but ≤25 kg (non-TI scope in Annex II).

Additional components (Annex III, for use in UAS):

• 8807.10.0015 – Propellers and rotors and parts thereof for use in civil aircraft, for use by DoD or USCG.
• 8807.10.0030 – Propellers and rotors and parts thereof for use in civil aircraft, not for use by DoD or USCG.
• 8807.10.0060 – Propellers and rotors and parts thereof, for use in aircraft other than civil aircraft.
• 8807.20.0015 – Undercarriages and parts thereof for use in civil aircraft, for use by DoD or USCG.
• 8807.20.0030 – Undercarriages and parts thereof for use in civil aircraft, not for use by DoD or USCG.
• 8807.20.0060 – Undercarriages and parts thereof, for use in aircraft other than civil aircraft.
• 8807.30.0015 – Other parts of airplanes or helicopters, nesoi, for use in civil aircraft, for use by DoD or USCG.
• 8807.30.0030 – Other parts of airplanes or helicopters, nesoi, for use in civil aircraft, not for use by DoD or USCG.
• 8807.30.0060 – Other parts of airplanes or helicopters for use in aircraft other than civil aircraft (excluding propellers, rotors, undercarriages and parts thereof).
• 8807.90.9015 – Other parts, nesoi, for use in civil aircraft, for use by DoD or USCG.
• 8807.90.9030 – Other parts, nesoi, for use in civil aircraft, not for use by DoD or USCG.
• 8807.90.9060 – Other parts, nesoi, for use in aircraft other than civil aircraft, spacecraft and spacecraft launch vehicles (excluding parts of communication satellites).

4. Duty rates and structure

4.1 General Section 232 rates

• 100% ad valorem additional duty (Annex I / 9903.08.21):
• Applies to:

– UAS with maximum take-off weight >25 kg (HTS 8806.24.00, 8806.29.00, 8806.94.00, 8806.99.00).

– UAS with thermal imaging (TI) under 8806.21.00, 8806.22.00, 8806.23.00, 8806.91.00, 8806.92.00, 8806.93.00.

– UAS docking stations and certain critical components (e.g., 8504.40.9580, 8537.10.9170, and specified 8807.x Part items for UAS >25 kg, excluding retail delivery, agricultural use, or sale to DoW).

• Implemented via heading 9903.08.21: “The duty provided in the applicable subheading + 100%.”

• 25% ad valorem additional duty on UAS ≤25 kg without thermal imaging (Annex II / 9903.08.22):
• Applies to UAS under 8806.21.00, 8806.22.00, 8806.23.00, 8806.91.00, 8806.92.00, 8806.93.00 when they do not have thermal imaging.
• Implemented via heading 9903.08.22: “The duty provided in the applicable subheading + 25%.”

• 25% ad valorem additional duty on UAS components (Annex III and U.S. note 43(c)(5)):
• Applies to specified 8807.x components when imported for use in UAS.
• Effective February 9, 2027, via 9903.08.22 (after amendment to include parts and components under (c)(4) and (5)).

4.2 Capped rates for certain partner countries (clause (4) of proclamation)

• For products of Japan, Republic of Korea, Taiwan, Switzerland, Liechtenstein, or EU member states:
• Duty rate shall be no higher than 15% ad valorem, including the Column 1 duty rate.
• Implemented via 9903.08.24: for items with Column 1 duty <15%, the sum of Column 1 duty and the additional duty under 9903.08.24 equals 15%.

• For products of the United Kingdom:
• Duty rate shall be no higher than 10% ad valorem, including the Column 1 duty rate.
• Implemented via 9903.08.23: “The duty provided in the applicable subheading + 10%.”

Conditions:

• These capped rates apply only if “substantially all” critical components and technology are certified by importers to be products of the United States, Japan, Korea, Taiwan, Switzerland, Liechtenstein, EU member states, or the UK.
• The Secretary of Commerce will establish a process and inform CBP which products qualify.

4.3 Onshoring-related Chapter 99 provisions

• 9903.08.25 (until February 9, 2027):
• Applies to UAS, parts and components imported for companies subject to an onshoring plan approved by DHS or DoW.
• Duty: “No change” – i.e., no additional Section 232 duty; only base HTSUS duty applies.
• This heading is terminated and deleted effective February 9, 2027.

• 9903.08.26:
• Applies to UAS, parts and components imported subject to an onshoring plan approved by the Secretary of Commerce.
• Duty: “No change” – no additional Section 232 duty while the facility is under construction, within approved volumes.

5. Other key operational rules

5.1 Interaction with FTAs, preference programs, and other duties

• For goods eligible for special tariff treatment under FTAs or preference programs (GN 3(c)(i)):
• Additional duties under 9903.08.21–9903.08.26 are collected in addition to any special rate under the base subheading.

• Chapter 98 claims:
• Goods entered under Chapter 98 remain eligible, but additional Section 232 duties still apply as prescribed.

• Chapter 99 claims:
• No claim may be made under another Chapter 99 provision to obtain a lower rate or duty-free treatment that would undercut these Section 232 duties.

• ADD/CVD and other duties:
• All antidumping, countervailing, and other duties and charges continue to apply in addition to these Section 232 duties.

5.2 Drawback limitations (clause (8))

• Only manufacturing drawback under 19 U.S.C. 1313(a)–(b) is available for these Section 232 duties, and only if all of the following are met:
• The article is not of a type subject to an ADD or CVD order (regardless of country of origin).
• The article is a product of “Trade Agreement Partners” (UK, EU, Switzerland, Liechtenstein, Japan, Korea, Mexico, Canada, and any future partner with a trade and security agreement).
• At least 85% of the content of the article is a product of Trade Agreement Partners.

5.3 Foreign Trade Zones (FTZ) (clause (9))

• Any product described in Annex I, II, or III (except those eligible for admission as “domestic status” under 19 C.F.R. 146.43) that is subject to these duties and admitted into a U.S. FTZ on or after the effective date must be admitted as “privileged foreign status” (19 C.F.R. 146.41).
• Upon entry for consumption, such goods will be subject to the applicable ad valorem rates based on their HTSUS classification, including the Section 232 Chapter 99 duties.

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

6.1 Classification and product scoping

• Review all product lines involving:
• UAS (drones) under HTS 8806.x.
• UAS docking stations and control systems potentially classifiable under 8504.40.9580 or 8537.10.9170.
• Aircraft parts under 8807.x that are used in or with UAS.

• Confirm correct base HTSUS classification at the 10-digit level, especially:
• Distinguish between civil vs. non-civil aircraft parts (8807.10.00xx, 8807.20.00xx, 8807.30.00xx, 8807.90.90xx).
• Confirm maximum take-off weight categories and whether the UAS has thermal imaging.

• Determine whether each import is:
• A UAS with thermal imaging (Annex I, 100% duty).
• A UAS without thermal imaging and ≤25 kg (Annex II, 25% duty).
• A UAS >25 kg (Annex I, 100% duty).
• A component for use in UAS >25 kg (Annex I, 100% duty) or other UAS components (Annex III, 25% duty from February 9, 2027).

6.2 Chapter 99 reporting

• For each covered entry line on or after the relevant effective date:
• Report the appropriate Chapter 99 number (9903.08.21, 9903.08.22, 9903.08.23, 9903.08.24, 9903.08.26, or 9903.08.20 as applicable) in addition to the base HTSUS classification.
• Ensure that only one of 9903.08.21–9903.08.26 is used per line, consistent with the mutual exclusivity rule.

• For qualifying UK/EU/Japan/Korea/Taiwan/Switzerland/Liechtenstein products meeting content criteria:
• Coordinate with the Secretary of Commerce’s process and CBP guidance to determine eligibility for 9903.08.23 or 9903.08.24.
• Maintain documentation supporting origin and content (to demonstrate “substantially all” critical components and technology are from permitted countries).

6.3 Country-of-origin and content certification

• For potential use of 9903.08.23 or 9903.08.24 capped rates:
• Map supply chains to identify origin of critical components and technology.
• Develop internal procedures to certify content as required by the Secretary of Commerce.
• Prepare to provide supporting documentation to CBP upon request.

6.4 Onshoring incentive program

• Evaluate eligibility for onshoring benefits if planning or considering U.S. manufacturing of UAS or UAS components:
• Prepare onshoring plans including:

– Commitment to build, refurbish, or expand a U.S. facility producing covered products.

– Construction start and completion timelines (construction must occur before January 20, 2029).

– Projected annual production volumes and milestones.

• Submit plans to the Department of Commerce (and, where applicable, align with FCC Conditional Approval and DoW/DHS processes).
• If approved, coordinate with CBP to import covered products and necessary production equipment without Section 232 duties under 9903.08.26 (and, before February 9, 2027, potentially 9903.08.25 where applicable).
• Implement internal controls and reporting to comply with monitoring and avoid retroactive rescission of benefits.

6.5 FTZ and drawback strategy

• FTZ:
• For UAS and components admitted into FTZs on or after the effective dates, ensure admission as privileged foreign status where required.
• Reassess FTZ usage and production strategies given that Section 232 duties will apply upon entry for consumption.

• Drawback:
• Review drawback programs to confirm whether manufacturing drawback under 1313(a)–(b) is available for your products.
• Verify that products meet the Trade Agreement Partner origin and 85% content requirements if seeking drawback of Section 232 duties.

6.6 Systems, contracts, and pricing

• Update internal ERP and broker instructions to:
• Add new Chapter 99 codes and logic for when to apply each.
• Reflect new duty rates (100% or 25% additional) in landed cost calculations.

• Review and, if necessary, renegotiate contracts and pricing with suppliers and customers to account for increased duty costs.

• Consider supply chain adjustments:
• Shift sourcing to U.S. or qualifying partner countries where feasible.
• Evaluate redesigns to avoid thermal imaging where not essential, or to change weight categories, while ensuring accurate classification.

7. References

• Proclamation: “Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components into the United States” (August 13, 2026) – White House.
• Annex I (100% duty list): https://www.whitehouse.gov/wp-content/uploads/2026/08/ANNEX-I-1.pdf
• Annex II (25% duty on UAS ≤25 kg without thermal imaging): https://www.whitehouse.gov/wp-content/uploads/2026/08/Annex-II-1.pdf
• Annex III (25% duty on UAS components for use in UAS): https://www.whitehouse.gov/wp-content/uploads/2026/08/Annex-III.pdf
• Annex IV (HTSUS Chapter 99 modifications, U.S. note 43, 9903.08.20–.26): https://www.whitehouse.gov/wp-content/uploads/2026/08/Annex-IV.pdf

8. Ongoing monitoring

• The Secretary of Commerce will:
• Monitor imports of UAS and components and may add additional components to the tariff scope via Federal Register notice.
• Provide an update to the President within 120 days of the proclamation and periodically thereafter.

• Importers should:
• Monitor Federal Register notices from Commerce and DHS, and CBP guidance, for:

– Additional HTS codes added to the Section 232 scope.

– Detailed certification procedures for capped rates and onshoring plans.

– Any technical corrections to Annexes or U.S. note 43.

• Adjust compliance procedures promptly as new guidance is issued.