On April 2, 2026, President Trump signed a proclamation making significant structural changes to the Section 232 tariff regimes for steel, aluminum, and copper, effective April 6, 2026. The proclamation establishes a new framework for determining applicable tariff rates and modifies which derivative articles are covered. An accompanying fact sheet is available here.
NMMA is continuing to review the proclamation and its annexes. We encourage members to work with their suppliers to identify the HTS codes corresponding to imported components, parts, or products and assess the effect under the new full-value tariff structure and potential exemptions.
New Tariff Rate Structure
The proclamation establishes the following additional rates, applied to the full customs value of the imported article:
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No Section 232 tariffs on steel, aluminum, or copper articles listed in Annex II, including some marine products.
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50% on full value of steel and aluminum articles, certain derivative articles, and copper articles listed in Annex I-A.
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25% on full value of derivative articles of steel, aluminum, and copper listed in Annex I-B.
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10% for articles with U.S.-origin metal content.
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Note: The steel, aluminum or copper was smelted and cast in the U.S.
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No Section 232 tariffs on articles outside of chapters 72, 73, 74 and 76 of the Harmonized Tariff Schedule if the aggregated weight of steel, aluminum and copper content is 15% or less of the entire article.
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Note: Annex IV lays out the criteria for determining whether an article would meet this exemption.
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Reduced rate temporarily for certain industrial and electrical grid equipment listed in Annex III.
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15% percent through December 31, 2027
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Reverts to 25% thereafter
Inclusion Process Eliminated
The proclamation also ends the Section 232 inclusion process for derivative products, which allowed domestic producers to request articles to be subjected to the Section 232 aluminum and steel tariffs - NMMA submitted
dozens of comments opposing the potential inclusion of certain marine products.
However, the Department of Commerce and the U.S. Trade Representative can add derivative articles on a rolling basis when they jointly determine that imports of those articles threaten national security.
Existing Agreements Remain Intact
Products from the United Kingdom, the European Union, Japan, and South Korea will continue to receive reduced rates consistent with their existing agreements with the United States.
NMMA will continue working with the administration, Congress, and industry partners to ensure U.S. trade policy is targeted, balanced, and aligned with the needs of American manufacturers.
For more information, contact NMMA's Clay Crabtree, interim vice president of public policy & government affairs, at
[email protected].