On April 2, 2026, President Trump issued a Proclamation under Section 232 titled “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” significantly expanding and clarifying the application of additional duties on imports of steel, aluminum, copper, and their derivative products. Effective for goods entered for consumption or withdrawn from warehouse on or after 12:01 a.m. EST on April 6, 2026, the Proclamation imposes additional ad valorem duties ranging from 10% to 50%, applied to the full customs value of the imported merchandise rather than only the metal content.
The Proclamation establishes a structured tariff framework based on the product type and composition. Articles made entirely or almost entirely of aluminum, steel, or copper, and certain derivative products identified in Annex I-A will generally be subject to a 50% duty rate. Products from the United Kingdom may qualify for a reduced 25% rate when strict origin requirements are met, specifically when the aluminum is entirely smelted or cast in the UK, or the steel is entirely melted and poured in the UK. A reduced rate of 10% applies to qualifying derivative products made entirely from U.S.-origin metals, which are aluminum, steel, or copper that is fully smelted and cast, or melted and poured, in the United States.
For products listed in Annex I-B, including certain copper articles and derivative aluminum and steel products, the duty rate is 25%. Reduced rates of 15% apply to qualifying UK-origin materials under similar origin rules, while a 10% rate applies to products made entirely from U.S.-origin metals.
Certain industrial equipment and metal-intensive goods listed in Annex III are subject to a transitional tariff structure through December 31, 2027. Under this framework, goods with a normal Column 1 duty rate below 15% will be subject to an effective total duty rate of 15 %, while goods already at or above 15% will not incur additional Section 232 duties. Preferential 10% rates remain available for U.S.-origin metal content, while a 25% rate applies to products imported from countries that do not maintain normal trading relations with the United States. Beginning January 1, 2028, Annex III products will transition to the Annex I-B tariff structure.
For goods covered under Annex I-B or Annex III that are not classified in HTS Chapters 72, 73, 74, or 76, an exemption applies where the relevant metal content represents less than 15% of the product’s total weight. This threshold must be calculated in accordance with Annex IV, which identifies the specific metals to be considered for each HTS classification. Where a product is identified as a derivative of multiple covered metals, such as steel and aluminum, the combined weight of those metals must be used in determining whether the 15% threshold is met, while any non-specified metals are excluded from the calculation.
The Proclamation removes certain previously covered products from Section 232 duties, listed in Annex II, and terminates the formal product exclusion request processes established under earlier proclamations. However, it grants new authority to the Secretary of Commerce and the U.S. Trade Representative to expand the scope of covered derivative products at any time if import levels are deemed to threaten national security, including the ability to capture goods such as metal containers even when filled with non-subject merchandise.
Importers of covered copper products will be required to provide detailed information on where the copper was smelted and cast, with implementation of these reporting requirements expected as soon as practicable. The Proclamation also maintains the previously imposed 200% duty on aluminum products connected to Russia, including cases where any primary aluminum used in the product was smelted or cast in Russia.
Goods subject to these tariffs that enter foreign trade zones on or after April 6, 2026, must be admitted under privileged foreign status. The Proclamation also significantly limits duty drawback eligibility. Drawback is only permitted for certain qualifying goods listed in Annex I-B or Annex III that are not subject to antidumping or countervailing duties, are sourced from specified trade agreement partners, and are made entirely from metals produced in those partner countries. Outside of these specific conditions, drawback is not available for duties imposed under this action.
Lastly, the Proclamation confirms that existing agreements with key trading partners, including those covering civil aircraft and related parts under World Trade Organization commitments, remain in effect and are not superseded. It also establishes ongoing monitoring and review mechanisms, requiring government agencies to assess the impact of imports on national security and report back within 90 days, with authority to modify, expand, or revoke tariff measures as needed.
The Annexes are available at the following link: ANNEXES-I-A-I-B-II-III-IV
The full Proclamation and supporting Fact Sheet are available here:
Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper into The United States
Fact Sheet: Donald J Trump Strengthens Tariffs on Steel, Aluminum, and Copper Imports