New Section 232 Duties on Imports
of Aluminum, Steel, and Copper Import into US
Key Highlights
·
Proclamation Issued:
o On April 2, 2026, the U.S. President
announced new duties under Section 232 of the Trade Expansion Act of 1962.
o Duties range from 10% to 50% on
imports of aluminum, steel, copper, and their derivatives.
o Effective April 6, 2026.
·
Duty Structure:
o General Imports: 50% ad valorem duty (HTSUS 9903.82.02).
o Low Metal Content (<15%): 0% duty (HTSUS 9903.82.03).
o UK-Origin Products: 25% duty for primary aluminum/steel; 15% duty for derivative articles (HTSUS 9903.82.04–05).
o U.S.-Origin Derivatives: 10% duty if 95% of metal content is
U.S.-sourced (HTSUS 9903.82.06).
o Copper Articles: 25% duty (HTSUS 9903.82.09).
o Russian-Origin Products:
§ Steel/copper derivatives: 10–50% duty
(HTSUS 9903.82.14–17).
§ Aluminum: 200% duty (HTSUS 9903.85.67–68).
·
Special Provisions:
o Motorcycle Parts: 0% duty if used in U.S. manufacturing
(HTSUS 9903.82.13).
o Civil Aircraft Agreements: Prior trade deals with UK, EU, Japan,
Korea remain unaffected.
o Foreign Trade Zones (FTZs): Imports must enter under “privileged
foreign status.”
o Drawback Claims: Allowed under Section 313 of the Tariff
Act of 1930.
·
Reporting Requirements:
o Importers must declare country of melt
and pour (steel) and smelt and cast (aluminum).
o Copper reporting requirements to be announced
later.
·
Timeline:
o Duties effective April 6, 2026.
o Certain headings (9903.82.07–12) apply
until December 31, 2027, after which new duty rates (9903.82.05–09) will
apply from January 1, 2028.
Strategic Impact
·
Reinforces U.S. trade defense under Section
232.
·
Targets Russian aluminum with 200% tariff,
signaling strong geopolitical stance.
·
Encourages domestic sourcing of steel, aluminum,
and copper.
·
Provides exemptions for low-content goods and critical industries (motorcycles,
civil aircraft).
[ABS News Service/04.04.2026]
CSMS # 68253075/02.04.2026-
GUIDANCE:
The purpose of this message is to provide
guidance on the implementation of the April 2, 2026, Proclamation, “Strengthening
Actions Taken to Adjust Imports of Aluminum, Steel, and
Copper into the United States.”
BACKGROUND
In April 2, 2026, the President issued
a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section
232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). This proclamation imposes 10-50% additional duties
on the full customs value of certain imports of steel, aluminum,
copper articles (metal articles) and their derivatives from all countries, effective
April 6, 2026.
Goods that are listed as articles or derivatives
of more than one metal shall only be subject to one of the respective duty rates
established by this Proclamation, even if the good contains aluminum
and steel, aluminum and copper, steel and copper, or all
three metals.
Goods specified in the annexes to the
Proclamation that do not contain any aluminum, steel,
or copper content shall not be subject to the duties imposed by the Proclamation.
In addition, goods specified in the annexes
to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76 of
the Harmonized Tariff Schedule of the United States (HTSUS), that contain less than
15 percent of the aggregate weight of the applicable metal(s) shall not be subject
to the duties imposed by the Proclamation.
The applicable metals, based on HTSUS classification, are identified in paragraphs
(c)(i) through (x) of annex IV of the Proclamation. Do not include the weight of a metal in the 15
percent calculation where annex IV does not specify a metal for a specific HTSUS
classification.
For example, since HTSUS is 8302.10.60
is identified in paragraphs (c)(vi) and (vii) of annex IV as both a derivative aluminum article and steel article in annex IV, the aggregate
weight of both aluminum and steel (but not copper) should
be included in the 15 percent calculation.
ENTRY FILING GUIDANCE
This guidance provides instructions for
importers, brokers, and filers on submitting entries to U.S. Customs and Border
Protection (CBP) on certain steel, aluminum, and copper
articles and their derivatives from all countries as provided in HTSUS headings
9903.82.02–9903.82.17. See the attachment
for the Chapter 1 to 97 HTSUS classifications which correspond to each Chapter 99
heading.
The additional duties will take effect
with respect to goods entered for consumption, or withdrawn from warehouse for consumption,
on or after 12:01 a.m. eastern time on April 6, 2026.
Headings 9903.82.07, 9903.82.08, 9903.82.10,
9903.82.11, and 9903.82.12 are effective with respect to goods entered for consumption
or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time
on April 6, 2026, and before January 1, 2028.
Effective with respect to goods entered
for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m.
eastern time on January 1, 2028, the goods covered by headings 9903.82.07, 9903.82.08,
9903.82.10, 9903.82.11, and 9903.82.12 will be subject to the duty rates under HTSUS
9903.82.05, 9903.82.06, and 9903.82.09. Additional
guidance will be provided prior to January 1, 2028.
9903.82.02: Except as provided for in headings 9903.82.14,
9903.85.67 and 9903.85.68, applies to articles of aluminum,
of steel, or of copper and derivative aluminum or steel
articles, as provided for in subdivision (c)(i)-(v) of U.S. note 16 to this
subchapter.
50% additional ad valorem
rate of duty
9903.82.03: Except for articles classifiable in chapters
72, 73, 74, or 76, articles where the weight of the applicable metal is less than
15 percent of the weight of the imported article, as provided for in subdivision
(c) of U.S. note 16 to this subchapter.
0% additional ad valorem rate of duty
When reporting HTSUS 9903.82.03, report
the aggregate weight of the applicable metal(s) in kg as a second quantity on the
entry summary line.
9903.82.04: Applies to articles of aluminum or of steel and derivative aluminum
or steel articles that are the product of the United Kingdom in which at least 95
percent of the aluminum was smelted or most recently cast
in the United Kingdom, or in which at least 95 percent of the steel was melted and
poured in the United Kingdom as provided for in subdivisions (c)(i)-(iv) and (d) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.05: Applies to derivative aluminum or steel articles that are the product of the United
Kingdom in which at least 95 percent of the
aluminum was smelted or most recently cast in the
United Kingdom, or in which at least 95 percent of the steel was melted and poured
in the United Kingdom as provided for in subdivisions (c)(vi)-(vii) and (d) of U.S.
note 16 to this subchapter.
15% additional ad valorem rate of duty
Headings 9903.82.06, 9903.82.07, and 9903.82.08
apply to certain articles of copper and derivative aluminum
and steel articles provided for in subdivision (c) of this note.
·
For derivative articles provided for in subdivisions (c)(ii), (vi), and (ix),
at least 95 percent of the aluminum content of the article
must be composed of aluminum that was smelted and cast
in the United States.
·
For derivative articles provided for in subdivisions (c)(iv), (vii), and
(x), at least 95 percent of the steel content of the article must be composed of
steel that was melted and poured in the United States.
·
For articles provided for in subdivision (c)(viii), at least 95 percent of
the copper content of the article must be composed of copper that was smelt and
cast in the United States (see below for reporting requirements).
·
These requirements are cumulative such that a derivative article in more
than one subdivision must satisfy each requirement.
9903.82.06: Except as provided for in headings 9903.82.15
and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(ii),
(iv), (vi) - (viii), and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.07: Except as provided for in headings 9903.82.12,
9903.82.17 and 9903.85.68, applies to derivative aluminum
and steel articles, as provided in subdivisions (c)(ix)-(x)
and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable
column 1 duty rate is less than 10 percent, the sum of the column 1 duty rate and
the additional ad valorem rate of duty will be 10%.
9903.82.08: Except as provided for in headings 9903.82.12,
9903.82.17 and 9903.85.68, applies to derivative aluminum
and steel articles, as provided in subdivisions (c)(ix)-(x)
and (e) of U.S. note 16 to this subchapter.
For articles for which the applicable
column 1 duty rate is 10 percent or higher, no additional duty is due.
9903.82.09: Except as provided for in headings 9903.82.16
and 9903.85.68, applies to articles of copper and derivative aluminum and steel articles as provided in subdivisions (c)(vi)-(viii) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.10: Except as provided for in headings 9903.82.12,
9903.82.17 and 9903.85.68, applies to derivative aluminum
and steel articles, as provided for in subdivision (c)(ix)-(x)
and (f) of U.S. note 16 to this subchapter (not 95 percent melted and poured or
smelted and cast in the U.S.)
For articles for which the applicable
column 1 duty rate is less than 15 percent, the sum of the column 1 duty rate and
the additional ad valorem rate of duty will be 15%.
9903.82.11: Except as provided for in headings 9903.82.12,
9903.82.17 and 9903.85.68, applies to derivative aluminum
and steel articles, as provided for in subdivision (c)(ix)-(x)
and (f) of U.S. note 16 to this subchapter (not 95 percent melted and poured or
smelt and cast in the U.S.)
For articles for which the applicable
column 1 duty rate is 15 percent or higher, no additional duty is due.
9903.82.12:
Except as provided for in headings 9903.82.17 and 9903.85.68 applies to derivative
aluminum and steel articles, the product of any country
identified in general note 3(b) (countries subject to the column 2 duty rates in the HTSUS), as provided
for in subdivision (c)(ix)-(x) of U.S. note 16 to this
subchapter.
25% additional ad valorem rate of duty
9903.82.13: Applies to articles that otherwise meet
the criteria of subdivisions (c)(vi)-(viii) that are motorcycle
parts classifiable in chapter 84, 85, or 87 for use in the manufacturing of motorcycles
in the United States.
0% additional ad valorem rate of duty
9903.82.14: Applies to articles of steel or of copper
and derivative steel that are the product of the Russian Federation as provided
for in subdivisions (c)(iii)–(v) of U.S. note 16 to this subchapter.
50% additional ad valorem rate of duty
9903.82.15: Applies to articles of copper and derivative
steel that are the product of the Russian Federation, as provided for in subdivisions
(c)(iv), (vii), (viii) and (e) of U.S. note 16 to this subchapter.
10% additional ad valorem rate of duty
9903.82.16: Applies to articles of copper and derivative
steel that are the product of the Russian Federation, as provided for in subdivisions
(c)(vii)–(viii) of U.S. note 16 to this subchapter.
25% additional ad valorem rate of duty
9903.82.17: Applies to derivative steel articles that are the
product of the Russian Federation, as provided for in subdivision (c)(x) of U.S.
note 16 to this subchapter.
25% additional ad valorem rate of duty
Russia Aluminum
Duties
All imports of aluminum
articles and aluminum derivative articles covered by this
Proclamation that are the product of Russia or where any amount of primary aluminum used in the manufacture of these aluminum articles is smelt in Russia, or these aluminum articles are cast in Russia, shall continue to be subject
to the 200 percent ad valorem rate of duty under HTSUS heading 9903.85.67
for aluminum products; and heading 9903.85.68 for aluminum derivative products.
Russia aluminum
and aluminum derivative products subject to HTSUS headings
9903.85.67 and 9903.85.68 may not be reported under HTSUS 9903.82.03.
Reporting of Countries
of Melt and Pour and Smelt and Cast
Continue to report the countries of melt
and pour for all subject steel and steel derivative products and the countries of
smelt and cast for all subject aluminum and aluminum derivative products. See, e.g., Cargo System Messaging Service messages
64348411, 64348288, and 65340246 for reporting instructions.
CBP will issue a CSMS to announce when
the reporting of the countries of copper smelt and cast will be required and the
corresponding functionality is available in ACE for imports of copper products under
the following HTSUS classifications:8544.42.10; 8544.42.20; 8544.42.90; and 8544.49.10.
Prior Trade Agreements
This proclamation does not alter or supersede
actions implementing any prior agreements with the United Kingdom, European Union,
Japan, or Korea to reduce the tariffs imposed under section 232 on certain aluminum, steel, or copper articles and certain aluminum, steel, or copper derivative articles that fall under
the World Trade Organization Agreement on Trade in Civil Aircraft and either are
civil aircraft or are used as parts for civil aircraft.
Drawback
Manufacturing drawback claims made in
accordance with subsections (a) and (b) of section 313 of the Tariff Act of 1930,
as amended, 19 U.S.C. 1313(a)–(b), shall be available with respect to the duties
imposed by Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” for articles
that meet the conditions of clause 13.
Foreign Trade Zone (FTZ)
Products subject to this proclamation,
except those eligible for admission under “domestic status”, as defined in 19 CFR
146.43, that are subject to the duty imposed by this proclamation and that are admitted
into a U.S. foreign trade zone on or after the effective date of the Proclamation,
may be admitted only under “privileged foreign status” as defined in 19 CFR 146.41,
and any products admitted in “privileged foreign status” prior to the effective
date of the Proclamation will be subject upon entry for consumption to any ad valorem
rates of duty related to the classification under the applicable HTS subheading.
Chapter 98 and Chapter 99 Provisions
Goods for which entry is claimed under
a provision of chapter 98 to the HTSUS and that are subject to the additional duties
prescribed herein shall be eligible for and subject to the terms of such provision
and applicable CBP regulations, except that duties under subheading 9802.00.60 shall
be assessed based upon the full value of the imported article. No claim for entry or for any duty exemption or
reduction shall be allowed under a provision of chapter 99 to the HTSUS that may
set forth a lower rate of duty or provide duty-free treatment, taking into account
information supplied by CBP. All antidumping,
countervailing or other duties and charges applicable to such goods shall continue
to be imposed.