Steel, Aluminum & Copper Metals import compliance
Pin the 232 rate before metal ships.
The annex, the melt country and the plant decide what a metal part pays. GingerOS keeps the code, the reason and every Chapter 99 line on each part, for every entity.
GingerOS- HTS
7604.29.1090- Origin
- Canada
- Imported by
- Ontario plant, CA
- Entry
- 10/06/2026
Duty stackTotal duty100%
- Base duty (MFN)USMCA claim: special rate S
Not applied - Section 232, aluminum
9903.82.0250% - Section 338, Canada
9903.03.1450% - Section 301, forced laborNote 52(f): Section 232 articles are exempt
9903.05.29Not applied
Plus MPF 0.3464%, and HMF 0.125% by ocean
Why A Chapter 76 profile pays the 50% aluminum duty on full value even under USMCA. Since September 15, 2026 the 50% Section 338 duty on Canadian extrusions stacks on top of it.
A GingerOS part record with demo data for steel, aluminum & copper: Aluminum alloy profile, extruded, HTS 7604.29.1090, from Canada. Each duty layer is listed with its rate or exemption, for a total duty of 100%.
What do steel, aluminum and copper pay now?
Section 232 on full value: 50% or 25% by annex, a combined 15% for listed equipment, 10% for U.S. metal.
Since April 6, 2026, Section 232 applies to the full customs value of steel, aluminum and copper articles and listed derivatives: 50% for Annex I-A, 25% for Annex I-B, a combined 15% for Annex III equipment through 2027, and 10% where at least 85% of the metal is U.S. melted or smelted. USMCA does not remove it. Section 232 articles are exempt from the forced-labor Section 301, but antidumping duties, China-list 301 and, for Canadian extrusions, a 50% Section 338 duty stack on top.
Recent Policy UpdatesNotices that touch steel, aluminum and copper
- Presidential ProclamationProclamation 11021Steel, aluminum and copper 232 on full value: 50%, 25%, 15% or 10% by annex
One metals duty per article, on its whole value; outside Ch. 72 to 76 it applies only at 15% metal by weight or more.
Ch. 72, 73, 74, 76; 9903.82.01 to 9903.82.26Read the explainer - Presidential ProclamationProclamation 11032Annex I-C mobile equipment tier added; U.S.-metal threshold cut to 85%
Forklifts and dozers pay 25% with 15% caps for listed partners, and 85% U.S. metal by weight now earns the 10% rate.
8427.10, 8427.20, 8429.19, 8429.20 - Presidential ProclamationProclamation 1106550% Section 338 duty now stacks on Canadian aluminum extrusions and steel structures
Canadian 7604, 7608 and 7308.90 lines pay Section 338 on top of Section 232, with no USMCA exemption.
7604, 7608, 7308.90; 9903.03.14Read the explainer - Federal Register Notice90 FR 59494New antidumping orders on corrosion-resistant steel from 10 countries
Orders cover CORE from Australia, Brazil, Canada, Mexico, the Netherlands, South Africa, Taiwan, Türkiye, the UAE and Vietnam, collected on top of 232.
Scope text governs, typically Ch. 72 flat-rolled
A Compliance Radar feed of 4 recent policy updates that touch steel, aluminum & copper, each with its source, reference and effective date.
Is this extrusion a profile or a battery part?
A general profile pays 50% aluminum 232 on full value; cut and notched for one battery, it is a battery part in the auto bucket.
Aluminum alloy extrusion, cut to length and notched, used as an internal frame member of an EV battery pack.
Ginger asksAs imported, is it cut and notched for one battery assembly, or still a length of profile for general use?
Cut and notched for one pack design. It has no other use.
8507.90.8000HTS rate 3.4%
Parts of electric storage batteries: other
Section 232 auto parts: 25%, or 0% under USMCA (9903.94.06)
7604.29.1090HTS rate 5%
Aluminum alloy profiles: other
Section 232 aluminum: 50% of full value; from Canada, Section 338 at 50% too
Deciding rule Section XV Note 1(f) keeps Section XVI goods out of Chapter 76; Section XVI Note 2(b) sends a part used solely or principally with one kind of machine to that machine's heading. CBP ruling N351604 (August 11, 2025) put a notched aluminum extrusion support for an EV battery in 8507.90.8000. Antidumping scope is decided separately by Commerce.
A Classification Researcher conversation with demo data. Ginger asks: As imported, is it cut and notched for one battery assembly, or still a length of profile for general use? From the answer it picks HTS 8507.90.8000 over 7604.29.1090.
What does this mean for your metals team?
A new annex, a new melt country or a part cut for one assembly each reopens the rate, so each becomes a recheck.
GingerOSWhich of our metal parts changed annex, and what do the Canadian extrusions pay since September 15?
Open rechecks3
7604.29.1090Ontario plant, CAProclamation 11065: Section 338 on Canadian extrusionsRecalculate tariffs for the listed linesRuns in Compliance RadarRunning7604.29.1090Ontario plant, CAProfile now cut and notched for one packReclassify: a dedicated part, not a profileRuns in Classification ResearcherNeeds answer7326.90.8688Monterrey plant, MXMill switched to U.S.-melted steelRecheck the stack with the melt countryRuns in Tariff CalculatorReviewA GingerOS window with demo data. Someone asks: "Which of our metal parts changed annex, and what do the Canadian extrusions pay since September 15?" It lists 3 open rechecks, each with the part, HTS code, trigger, tool and status.
Questions about metals compliance
What is the Section 232 rate on steel and aluminum in October 2026?
It depends on the annex. Annex I-A articles and derivatives pay 50%, Annex I-B lines pay 25%, Annex III agricultural and fixed industrial equipment pays a combined 15% through December 31, 2027, and derivatives whose metal is at least 85% U.S. melted or smelted pay 10%, all on full customs value (Proclamations 11021 and 11032; U.S. note 16 to Chapter 99).
Is Section 232 charged on full value or only the metal content?
On the full customs value of the article, regardless of metal content, for entries on or after April 6, 2026 (Proclamation 11021, clause 1). The earlier metal-content method no longer applies. For articles outside Chapters 72, 73, 74 and 76, the duty applies only where the covered metal is at least 15% of the article's weight (U.S. note 16(c)).
Does Section 232 apply to USMCA-qualifying Canadian or Mexican steel and aluminum?
Yes. U.S. note 16(b) collects the Section 232 metals duties in addition to any USMCA preference rate. The exceptions are narrow: USMCA mobile industrial equipment in Annex I-C pays 25% on non-U.S. content with a 15% floor through 2027 (Proclamation 11032), and Commerce may authorize limited quantities at a reduced rate for producers supplying U.S. vehicle makers (Proclamation 10984, clause 13).
What changed for Canadian aluminum extrusions in September 2026?
Canadian aluminum profiles, bars and rods (7604), aluminum tubes (7608) and certain steel structures (7308.90) were added to the 50% Section 338 duty on September 15, 2026, and that duty now applies in addition to Section 232 (Proclamation 11065). A USMCA claim does not remove it, so a qualifying Canadian profile can carry 100% in combined added duty.
Does the forced-labor Section 301 duty apply to steel and aluminum?
No, not for articles covered by Section 232. U.S. note 52(f) exempts articles of aluminum, steel or copper and the derivatives entered under 9903.82.02 and 9903.82.04 through 9903.82.26 from the 10% and 12.5% duties in force since July 24, 2026 (91 FR 47318). Lead, zinc, tin and other base metals in Chapters 78 to 81 are not on the Section 232 lists, so they get no such exemption.
Can Section 232 metals duties be recovered through drawback?
Only narrowly. Manufacturing drawback under 19 U.S.C. 1313(a) and (b) is available for Annex I-B and Annex III articles that are products of the UK, EU, Japan, Korea, Mexico or Canada, made with metal melted or smelted in those partners, and not of a type subject to an antidumping or countervailing duty order. No other drawback applies (Proclamation 11021, clauses 13 and 14).
Which steel products got new AD/CVD orders in the past year?
Corrosion-resistant steel. Commerce issued antidumping orders on CORE from Australia, Brazil, Canada, Mexico, the Netherlands, South Africa, Taiwan, Türkiye, the United Arab Emirates and Vietnam, and countervailing orders on CORE from Brazil, Canada, Mexico and Vietnam, both published December 19, 2025 (90 FR 59494; 90 FR 59488). These duties are collected on top of Section 232.
Does an FTZ avoid the Section 232 metals duty?
No. Covered metal articles admitted to a foreign-trade zone on or after April 6, 2026 may be admitted only in privileged foreign status, which fixes the Section 232 classification and rate that apply when the goods are entered for consumption (Proclamation 11021, clause 12). A zone can still move the timing of the payment, but it does not lower the rate.
