Executive summary

On 2 April 2026, United States (US) President Trump issued a proclamation titled "Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States," modifying the tariff regimes established under Proclamations 9704 (aluminum), 9705 (steel), and 10962 (copper) pursuant to Section 232 of the Trade Expansion Act of 1962. The proclamation modifies the tariff regimes such that 25% ad valorem duties apply to the full customs value of covered articles and their derivatives, rather than a 50% ad valorem duty on the covered metal content alone, and clarifies the scope of products covered by these tariffs.

Full-value tariffs and rate structure

Effective for customs entries on or after 12:01 a.m. ET on 6 April 2026, the Section 232 additional ad valorem duties apply to the full customs value of aluminum, steel and copper articles and their derivative articles, and not just to the metal content.

Annex I-A to the proclamation consists of articles composed entirely of aluminum and steel, most copper articles, and specified aluminum/steel derivative articles. The general rate of duty for Annex I-A products is 50%, with reduced rates of 25% for United Kingdom (UK) products when all aluminum is smelted or most recently cast in the UK or all steel is melted and poured in the UK, and 10% for derivative articles made entirely with US-origin aluminum, steel or copper. (Note: Annex references in this Tax Alert all refer to those included in the proclamation, available here.)

Annex I-B consists of other copper articles and specified aluminum and steel derivative articles. The general rate is 25%, with reduced rates of 15% for qualifying UK-origin metal content and 10% for articles made entirely with US-origin content.

Products listed in Annex II are removed from Section 232 aluminum/steel tariff coverage as of 6 April 2026.

Annex III transitional framework (through 31 December 2027)

Annex III consists of certain products, including machinery and metal-, plastic- and rubber-forming molds, dies and tools. For Annex III products entered on or after 6 April 2026 and until 11:59 p.m. ET on 31 December 2027, the applicable rate is calibrated against the Harmonized Tariff Schedule of the United States (HTSUS) Column 1 (general) duty rate:

• If Column 1 is less than 15%, the sum of Column 1 and the Section 232 rate equals 15%.
• If Column 1 is at least 15%, the Section 232 rate is 0%.

A 10% rate applies to Annex III derivative articles made entirely with US-origin aluminum or steel, while a 25% rate applies to imports from trading partners without normal trading relations.

Beginning 1 January 2028, Annex III products transition to the Annex I-B rates.

The US Department of Commerce (Commerce) and the Office of the US Trade Representative (USTR) may revoke Annex III benefits for a trading partner if import surges undermine the regime's objectives; affected products then default to Annex I-B treatment.

Scope clarifications and exclusions

If goods in Annex IA, IB or III are listed as articles or derivatives of multiple metals, the product is subject to the applicable duty rate only once. Goods in Annex IB or III that contain no aluminum, steel or copper content (as defined in Annex IV), or that are not classifiable in HTSUS Chapters 72, 73, 74 or 76 and lack sufficient metal content per Annex IV, are excluded from these duties. The proclamation does not alter prior actions implementing agreements with the UK, the European Union (EU), Japan, the Republic of Korea or other partners under the World Trade Organization (WTO) Agreement on Trade in Civil Aircraft for civil aircraft and parts.

Derivative coverage and inclusion process

The derivative inclusion processes established in 2025 are terminated. Commerce and USTR are authorized to add derivative aluminum, steel or copper articles on a rolling basis when imports threaten to impair national security, contribute to identified national security threats or undermine the regime's objectives. This authority explicitly allows metal containers to be brought under tariff scope, even if filled with items not otherwise subject to metal tariffs. Newly added derivatives generally receive the Annex IB rate structure, unless identical or substantially comparable to Annex IA articles (in which case Annex IA rates apply). Additions take effect upon the publication of a Federal Register notice. Commerce and USTR may reconsider or reverse inclusion decisions.

Russian aluminum and enforcement

All aluminum articles and aluminum derivatives in Annex I-A, I-B, or III that are of Russian origin, use primary aluminum smelted in Russia, or are cast in Russia remain subject to the 200% duty established in Proclamation 10522. US Customs and Border Protection (CBP) has been directed to administer and enforce the strengthened regime, including rules and guidance to identify metal content and origin, address illegal transshipment and undervaluation, and require importers to provide smelt and cast origin information for covered copper articles.

Foreign trade zones and drawback

Covered products admitted to US Foreign Trade Zones (FTZs) on or after the effective date must be admitted in privileged foreign status. Products admitted in privileged foreign status prior to the date will be subject to applicable ad valorem rates upon entry for consumption. Products admitted in privileged foreign status prior to the date will be subject to applicable ad valorem rates upon entry for consumption.

Manufacturing drawback is available under strict conditions for goods in Annex I-B or Annex III (or included per clause (11)) that are not subject to antidumping or countervailing duty (AD/CVD) orders and are products of specified Trade Agreement Partners (UK, EU, Japan, Republic of Korea, Mexico, Canada and partners with final reciprocal trade agreements), with all metal content, smelt and cast in the case of aluminum, or melted and poured in the case of steel, in a Trade Agreement Partner. No other drawback claims are allowed.

Administration and monitoring

Commerce and the USTR may modify the HTSUS and make technical corrections via a Federal Register notice. They must jointly provide an update within 90 days on import status relative to national security threats, domestic production, foreign partner actions and any relevant circumstances or recommendations. Relevant agencies have been directed to take appropriate measures to implement and effectuate the proclamation.

Actions to consider

Actions for businesses to consider, depending on their specific situations, include:

• Analyze customs valuation and, if applicable, the transfer pricing of finished goods to assess compliance and to identify structuring opportunities to exclude non-dutiable elements.
• Develop, maintain and audit tariff classifications to properly identify products within and outside of the scope of Section 232 tariffs.
• Recalculate landed costs by modeling full-value ad valorem duties at 50% (Annex I-A) and 25% (Annex I-B), and evaluate eligibility for reduced rates (10% for US-origin; 25%/15% for UK-origin) based on smelt, melt, pour and cast provenance for each metal content.
• Determine whether products qualify for transitional treatment under Annex III, apply the Column 1 interplay through 31 December 2027, and plan for the transition to clause (3) rates effective 1 January 2028.
• Confirm whether goods are excluded under Annex IV due to no or insufficient metal content and ensure that only one duty rate is applied to articles containing multiple metals.
• Monitor Federal Register notices for rolling inclusion of derivative articles, assess exposure for metal containers and other at-risk derivatives, and update HTSUS classification and compliance processes accordingly.
• Develop and maintain robust smelt, melt, pour, and cast origin documentation for aluminum, steel and copper to support reduced-rate claims and respond to CBP inquiries, ensuring supplier certifications and contracts are aligned.
• Modify FTZ and drawback strategies by admitting covered goods in privileged foreign status and evaluating eligibility for limited manufacturing drawback for Trade Agreement Partner products that meet content and AD/CVD requirements.
• Screen supply chains for Russian aluminum origin, smelt or cast to prevent inadvertent application of the 200% duty.
• Update internal systems and broker instructions to incorporate Annex I-A/I-B/III rate logic, reduced-rate conditions and exclusion rules, and prepare for increased CBP enforcement related to transshipment and undervaluation.