The White House issued a new proclamation modifying existing Section 232 tariff measures on steel, aluminum, and copper. The update expands the scope of derivative products subject to additional duties and changes how those duties are calculated.
Effective April 6, 2026, Section 232 tariffs will be assessed on the full customs value of covered products rather than only the value of the metal content. The annexes also introduce a broader set of derivative articles that fall within scope, with tariff treatment tied directly to HTSUS classification and product composition.
READ THE FULL-VALUE TARIFF SECTION 232 EXPANSION FACT SHEET HERE: https://www.whitehouse.gov/fact-sheets/2026/04/fact-sheet-president-donald-j-trump-strengthens-tariffs-on-steel-aluminum-and-copper-imports/
WHICH PRODUCTS ARE INCLUDED IN THE EXPANDED DERIVATIVE SCOPE?
Published with the proclamation, Annexes I-A, I-B, II, III & IV establish a detailed list of steel, aluminum, and copper derivative products that are now subject to additional duties. These products span multiple industries and include a wide range of fabricated goods, household equipment, industrial components, and construction-related materials.
The scope is defined at the HTSUS level rather than by general product category. For example, the annexes identify specific tariff provisions covering items such as non-electric domestic appliances, heating equipment, and fabricated metal components, along with numerous copper-based articles. Where a product appears more than once within the annexes, the additional duty applies only once and is not cumulative within the Section 232 framework.
DOWNLOAD THE FULL HTSUS PRODUCTS LIST HERE: https://www.whitehouse.gov/fact-sheets/2026/04/fact-sheet-president-donald-j-trump-strengthens-tariffs-on-steel-aluminum-and-copper-imports/
HOW ARE THE NEW EXPANDED SCOPE TARIFF RATES STRUCTURED?
The updated framework applies a tiered tariff structure based on product type and composition. Articles made primarily of steel, aluminum, or copper are subject to a 50% ad valorem duty on full value. Derivative articles identified within the annexes are generally subject to a 25% ad valorem duty, also applied to full value.
A separate group of products listed in Annex III qualifies for a temporary reduction in duty through December 31, 2027. These include certain industrial machinery, manufacturing equipment, and infrastructure-related components, which are subject to a reduced rate during the defined period.
Products that contain minimal amounts of covered metals may fall outside the scope of Section 232 tariffs depending on composition thresholds.
WHAT ROLE DOES PRODUCT COMPOSITION PLAY IN DUTY TREATMENT?
Product composition is now a central factor in determining tariff applicability and eligibility for reduced treatment. The annexes establish specific thresholds for U.S.-origin metal content. In certain cases, derivative products may qualify for alternative tariff treatment if they meet the following criteria:
- Steel content is at least 95% melted and poured in the United States.
- Aluminum content is at least 95% smelted and cast in the United States.
- Copper content is at least 95% smelted and cast in the United States.
For products that contain more than one covered metal, each applicable threshold must be satisfied independently.
HOW DOES THIS CHANGE IMPORT CLASSIFICATION AND ENTRY REQUIREMENTS?
The updated framework signals that Section 232 applicability is determined through classification and supporting product data. Importers must align HTSUS classification with the annex listings and ensure that product specifications support the declared tariff treatment. This includes confirming whether a product is included within Annex I, Annex I-B, or Annex III and whether it qualifies for any reduced rate provisions. Because tariff treatment now applies to the full customs value, classification decisions have a direct impact on total duty exposure.
Stay up-to-date on freight news with Green’s Weekly Freight Market Update by following us on LinkedIn. For continuous updates, make sure to check out our website at greenworldwide.com.
