Section 232 Duties on Imports of Aluminum, Steel, and Copper
Cargo Systems Messaging Service: CSMS # 68253075 – GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper
Below is a summary of the guidance provided by U.S. Customs Border Protection on the implementation of Proclamation “STRENGTHENING ACTIONS TAKEN TO ADJUST IMPORTS OF ALUMINUM, STEEL, AND COPPER INTO THE UNITED STATES” (April 2, 2026).
To review the full document, please click on the links below.
CSMS # 68253075 – GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper
BACKGROUND
- Main Action: On April 2, 2026, the President issued a proclamation under Section 232 of the Trade Expansion Act, imposing 10-50% additional duties on steel, aluminum, and copper imports from all countries, effective April 6, 2026.
- Scope of Coverage: The duties apply to the full customs value of certain metal articles and their derivatives, targeting imports that could impact national security interests.
- Single Duty Rule: Products containing multiple metals (aluminum, steel, copper, or combinations) are subject to only one duty rate, not multiple rates, even when containing all three metals.
- Metal-Free Exemption: Goods listed in the proclamation annexes that contain no aluminum, steel, or copper content are completely exempt from these additional duties.
- 15% Threshold Rule: Products in annexes (excluding HTSUS Chapters 72, 73, 74, and 76) containing less than 15% aggregate weight of applicable metals are exempt from duties.
- Metal Weight Calculation: The 15% calculation includes only metals specifically identified in annex IV for each HTSUS classification. For example, HTSUS 8302.10.60 includes both aluminum and steel weights but excludes copper in the calculation.
- Practical Impact: This proclamation significantly affects importers of metal products, requiring careful analysis of product composition and HTSUS classifications to determine applicable duty rates.
SECTION 232 DUTIES: ENTRY FILING GUIDANCE
- Affected Products: Steel, aluminum, and copper articles and their derivatives classified under HTSUS headings 9903.82.02 through 9903.82.17
- Reference Materials: Detailed attachment provides corresponding Chapter 1-97 HTSUS classifications for each Chapter 99 heading
- Primary Effective Date: Additional duties begin April 6, 2026, at 12:01 a.m. Eastern Time for goods entered for consumption or withdrawn from warehouse for consumption
Temporary Provisions (April 6, 2026 – December 31, 2027):
- Special Headings: 9903.82.07, 9903.82.08, 9903.82.10, 9903.82.11, and 9903.82.12 have limited-time effectiveness
- Duration: These specific classifications apply only from April 6, 2026, through December 31, 2027
- Transition Period: Provides importers with nearly two years under these temporary duty structures
Major Changes Starting January 1, 2028:
- Duty Rate Consolidation: Products previously covered under the five temporary headings will transition to standardized rates
- New Classifications: Goods will be subject to duty rates under HTSUS 9903.82.05, 9903.82.06, and 9903.82.09
- Future Guidance: CBP will issue additional Section 232 duty instructions before the January 1, 2028 transition date
Critical Action Items:
- Review Product Classifications: Verify your steel, aluminum, and copper imports against the provided HTSUS headings
- Plan for Implementation: Prepare systems and processes for the April 2026 effective date
- Monitor Updates: Stay alert for supplementary guidance before the 2028 transition
- Consult Documentation: Reference the official attachment for specific product classifications provided below from the department
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
9903.82.06, 9903.82.07, and 9903.82.08
- Three specific headings (9903.82.06, 9903.82.07, and 9903.82.08) govern copper articles and derivative aluminum and steel products
- Aluminum requirements: For designated derivative articles, at least 95% of aluminum content must be smelted and cast in the United States
- Steel requirements: For specified derivative articles, at least 95% of steel content must be melted and poured in the United States
- Copper requirements: For applicable articles, at least 95% of copper content must be smelted and cast in the United States (includes reporting obligations)
- Cumulative compliance: Articles falling under multiple subdivisions must satisfy all applicable requirements simultaneously
- Geographic mandate: All materials must originate from United States-based production facilities to meet compliance standards
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)โ(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)โ(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
- Continued High Tariffs: All aluminum articles and aluminum derivative products from Russia remain subject to a 200% ad valorem duty rate
- Scope of Coverage: Applies to products that are:
- Manufactured in Russia
- Use any amount of primary aluminum smelted in Russia
- Cast in Russia
- Specific Classifications:
- HTSUS 9903.85.67: Aluminum products
- HTSUS 9903.85.68: Aluminum derivative products
- Reporting Restriction: Russian aluminum and derivative products under the above HTSUS headings cannot be reported under HTSUS 9903.82.03
Reporting of Countries of Melt and Pour and Smelt and Cast
- Steel Products: Continue reporting countries of melt and pour for all subject steel and steel derivative products
- Aluminum Products: Continue reporting countries of smelt and cast for all subject aluminum and aluminum derivative products
- Reference Instructions: For detailed reporting guidelines, see Cargo System Messaging Service (CSMS) messages:
- Copper Products – Upcoming Requirement: CBP will issue a CSMS announcement when copper smelt and cast country reporting becomes mandatory
- Copper HTSUS Classifications affected:
- 8544.42.10
- 8544.42.20
- 8544.42.90
- 8544.49.10
- System Availability: ACE functionality for copper product imports will be announced when the reporting requirement takes effect
- Key Takeaway: Current Section 232 duties reporting on steel and aluminum continues, while copper reporting requirements are pending CBP announcement with corresponding system updates.
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 Section 232 duties 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)โ(b), shall be available with respect to the duties imposed by Proclamation, โStrengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,โ for articles that meet the conditions of clause 13.
Foreign Trade Zone (FTZ)
- Products covered by this proclamation must follow specific admission requirements into U.S. foreign trade zones
- Two status categories exist:
- Domestic status (as defined in 19 CFR 146.43) – eligible for standard admission
- Privileged foreign status (as defined in 19 CFR 146.41) – required for duty-subject products
- New admissions on or after the proclamation’s effective date must use privileged foreign status only
- Previously admitted products in privileged foreign status will face ad valorem duty rates when entering for consumption
- Duty classification follows applicable HTS (Harmonized Tariff Schedule) subheading requirements
Chapter 98 and Chapter 99 Provisions
- Products covered: All goods subject to this proclamation, except those with “domestic status” under 19 CFR 146.43
- Chapter 98 provisions: Goods claiming entry under HTSUS Chapter 98 remain eligible for those provisions but face additional duties prescribed in the proclamation
- Full value assessment: Duties under subheading 9802.00.60 must be calculated based on the complete value of the imported article
- Chapter 99 restrictions: No claims allowed under HTSUS Chapter 99 provisions that offer lower duty rates or duty-free treatment
- CBP information requirement: All determinations consider information supplied by Customs and Border Protection
- Existing duties maintained: All antidumping, countervailing, and other applicable duties continue to be imposed without interruption
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