Client Advisory: Presidential Proclamation Modifies Section 232 Duties on Aluminum, Steel and Copper

WHAT'S THE LATEST

On April 2, President Trump issued a Presidential Proclamation titled "Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States," modifying tariffs imposed under Section 232 of the Trade Expansion Act. U.S. Customs and Border Protection (CBP) issued initial implementation guidance via Cargo Systems Messaging Service (CSMS) #68253075 on April 3.

The Proclamation significantly changes how Section 232 duties are assessed on covered aluminum, steel, and copper articles, including certain derivative products.

Key Changes

1. Duty Assessment Methodology
   • Section 232 duties now apply to the full entered value of covered products, regardless of metal content.
   • Articles containing more than one covered metal are subject to only one Section 232 duty rate.
2. Scope Adjustments
   • The scope of Section 232 has changed, and many derivative products are no longer subject to Section 232 duties.
   • A 15% de minimis weight threshold now applies to certain products classified outside HTSUS Chapters 72, 73, 74, and 76.

These changes apply to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on April 6, 2026.

WHAT WE KNOW

Updated Section 232 Duty Rates

• 50% Additional Duty
  • Certain aluminum, steel, and copper articles identified in Annex I--A
  • Includes specified goods classified under HTSUS Chapters 72, 73, 74, and 76
  • Duty applies to the full entered value
• 25% Additional Duty
  • Certain aluminum, steel, and copper derivative products identified in Annex I--B
  • Duty applies to the full entered value
• 15% Total Duty (Temporary - Through December 31, 2027)
  • Certain metal-intensive industrial equipment and electrical grid equipment listed in Annex III
  • Total duty rate of 15%, inclusive of applicable MFN (Column 1) duty
• 10% Duty
  • Certain derivative articles where at least 95% of the applicable metal was:
    • Steel: melted and poured in the United States
    • Aluminum or copper: smelted and cast in the United States
  • Duty may be additional or inclusive of MFN, depending on the HTSUS provision
  • Determination is based on metal production, not country of origin
• 0% Duty
  • Products classified outside HTSUS Chapters 72, 73, 74, and 76 that contain less than 15% aggregate weight of the applicable metal(s), as determined under Annex IV
  • Certain motorcycle parts in HTSUS Chapters 84, 85, or 87, imported exclusively for use in U.S. motorcycle manufacturing

Special Considerations

• Russia-Origin Aluminum
  • Aluminum articles and derivatives that are products of Russia, or that contain aluminum smelted or cast in Russia, remain subject to 200% duties under existing HTS provisions.
• Reporting Requirements (Remain in Effect)
  • Country of melt and pour for steel and steel derivatives
  • Country of smelt and cast for aluminum and aluminum derivatives
• Additional CSMS guidance will be issued once copper smelt and cast reporting becomes available in CBP's Automated Commercial Environment (ACE).

Foreign Trade Zones (FTZ) and Drawback

• Covered products must be admitted to FTZs in privileged foreign status, unless eligible for domestic status.
• Manufacturing drawback remains available only where the specific conditions in the Proclamation are met. No other drawback claims are permitted.

SEKO'S GUIDANCE

SEKO recommends that importers:

• Review product coverage under Annexes I-A, I-B, II, III, and IV
• If products contain less than 15% aluminum, steel, or copper content by aggregate weight, engage your broker immediately to update documentation & product databases to ensure products are properly exempted from Section 232 upon entry.
• Validate melt-and--pour / smelt--and--cast documentation where reduced duty rates may apply
• Reassess landed cost models to account for duties applied to the full entered value
• Monitor future changes, as the Proclamation authorizes additions or removals of derivative products via Federal Register notice

SEKO will continue to monitor CBP implementation and issue updates as additional CSMS guidance and FAQs are released.

For questions regarding applicability or entry filing, please contact your SEKO representative, or email us at [email protected].