President Trump Orders 50 percent Section 232 Tariff on Copper Imports

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On July 30, 2025, President Trump issued a Presidential Proclamation1 that imposed a 50 percent tariff on the copper input value of imports of semi-finished copper and intensive copper derivative products effective August 1, 2025 and recommended domestic sales requirements on copper input materials and high-quality copper scrap.

Tariff order

The Presidential Proclamation imposes a 50 percent tariff under Section 232 on the copper input value of semi-finished copper and intensive copper derivative products beginning on August 1, 2025.

Scope of the tariff

All imports of semi-finished copper (such as copper pipes, wires, rods, sheets and tubes) and intensive copper derivative products (such as pipe fittings, cables, connectors and electrical components) will be subject to the 50 percent tariff. The Presidential Proclamation includes a technical annex listing the specific HTSUS codes subject to the tariffs. Notably, the tariff does not apply to raw forms of copper (e.g., ores, concentrates and mattes), anode and cathode material or copper scrap. 

Entry into force

The tariff will apply to goods entered for consumption or withdrawn from warehouses for consumption, on or after 12:01 a.m. eastern daylight time on August 1, 2025. The Presidential Proclamation does not include exceptions for goods already in transit to the United States.
Goods entered into US Foreign Trade Zones (“FTZs”) on or after August 1 must be designated as “privileged foreign status.” Upon entry for consumption, these goods will be subject to the applicable ad valorem duty rates based on their classification under the relevant Harmonized Tariff Schedule of the United States (“HTSUS”) subheading.

Application to copper input value

The 50 percent tariff will apply exclusively to the value of the copper content of the articles specified in the Presidential Proclamation. The remaining non-copper value of the articles will be subject to the tariffs imposed under the International Economic Emergency Powers Act (“IEEPA”) as outlined in Executive Order 14257 (“IEEPA Reciprocal Tariffs”), applicable to nearly all US trading partners, or the country-specific IEEPA tariffs imposed on Mexico, Canada and China under Executive Orders 14194, 14193 and 14195, respectively (“IEEPA Fentanyl Tariffs”), if applicable.  

On July 31, US Customs and Border Protection (“CBP”) issued guidance through its Cargo Systems Messaging Service (“CSMS”)2 on the application of the 50 percent tariff on all imports of semi-finished copper products and intensive copper derivative products, which mirrors requirements already in place for the Section 232 tariffs on steel and aluminum articles. This guidance includes instructions for submitting entries to CBP for the covered copper products and copper derivative products from all countries, as detailed in the newly created HTSUS headings 9903.78.01 and 9903.78.02. 

For entries under HTSUS 9903.78.01 where the 50 percent tariff applies, CBP’s reporting instructions are summarized as follows:

  • For articles composed entirely of copper, the duty must be reported based on the total entered value on a single entry summary line.
  • If the copper content value cannot be determined, the duty must be reported based on the total entered value on a single entry summary line.
  • For articles not composed entirely of copper, the value of non-copper content and copper content must  be reported on two separate entry summary lines: (1) non-copper content (first line): the total entered value minus the copper content value, zero percent Section 232 duties (HTSUS 9903.78.02), and all other applicable duties; and (2) copper content (second line): the copper content value, Section 232 duties (HTSUS 9903.78.01), quantity of copper content in kilograms (HTSUS 9903.78.01), and all other applicable duties.
  • The duty is based on the value of the copper content, determined according to the principles of the Customs Valuation Agreement (19 U.S.C. 1401a).

CBP’s guidance also provides a list of the copper HTSUS subheadings (as specified in the Annex to the July 30 Presidential Proclamation) that identify the imported semi-finished copper products and intensive copper derivative products subject to the Section 232 copper tariff. This list includes 70 HTSUS subheadings under Chapter 74 and 4 HTSUS subheadings under Chapter 85.3

Exclusion for automotive products

If an imported copper product is listed in the Annex of the Presidential Proclamation and is also subject to the Section 232 tariffs on automobiles and automobile parts, it will only be subject to the 25 percent Section 232 automotive tariff.

No duty drawback

No duty drawback will be available for duties imposed under the July 30 Presidential Proclamation.

Forthcoming “inclusions process”

The Presidential Proclamation instructs the Department of Commerce to establish an “inclusions process” for the copper tariff within 90 days of the date of the Presidential Proclamation; i.e., by October 28, 2025. Under this inclusions process, the Department of Commerce will have the authority to include additional derivative copper articles within the scope of the 50 percent tariff. Similar inclusion processes exist for the steel, aluminum and automotive Section 232 tariff actions, which the Department of Commerce has used to add new products to the tariffs with minimal notice or explanation. However, unlike those actions, the Presidential Proclamation relating to copper does not direct the Department of Commerce to create a public application process for inclusions.

Copper imports from the United Kingdom

Regarding copper imports from the United Kingdom, the Presidential Proclamation states that, consistent with the General Terms of the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal dated May 8, 2025, the United States plans to collaborate with the United Kingdom to implement a structured and negotiated strategy to address national security concerns in the copper sector.

Potential for future expansion

By June 30, 2026, the Department of Commerce must provide the President with an update on domestic copper markets, including refining capacity and the market for refined copper in the United States. Based on this report, the President will consider expanding the tariffs by imposing a phased universal import duty on refined copper, starting at 15 percent on January 1, 2027, and increasing to 30 percent on January 1, 2028. If the President decides to proceed, it is likely that he will issue a new Presidential Proclamation to implement the tariff expansion.

Domestic sales requirements on copper input materials and high-quality copper scrap

The Presidential Proclamation states that the President has determined that “copper input materials and high-quality copper scrap meet the criteria specified in section 101(b) of the [Defense Production Act], 50 U.S.C. 4511(b).” Based on this finding, the President directed the Department of Commerce to take “all appropriate action” to implement recommended domestic sales requirements. The Department of Commerce will likely issue separate legal guidance to implement the domestic sales requirements described in the Presidential Proclamation.

According to an accompanying fact sheet, the domestic sales requirements will consist of the following: 

  • Require that 25 percent of high-quality copper scrap produced in the United States be sold domestically and that the Department of Commerce establish an export licensing system for all copper scrap exports. According to the fact sheet, this action seeks to provide preferential access for domestic fabricators and secondary refiners.
  • Require that 25 percent of copper input materials (such as copper ores, concentrates, mattes, cathodes and anodes) produced in the United States be sold domestically—starting at 25 percent in 2027, increasing to 30 percent in 2028, and reaching 40 percent in 2029. According to the fact sheet, this measure aims to enhance US copper refining capacity by providing low-cost inputs as domestic refiners expand their operations.

Section 232 investigation report

The Section 232 Presidential Proclamation on copper was issued following an investigation into the effects of copper imports on US national security. The investigation, initiated on March 10 by the Department of Commerce Bureau of Industry and Security (“BIS”),4 focused on imports of copper in all forms, including, but not limited to: raw mined copper; copper concentrates; refined copper; copper alloys; scrap copper; and derivative products. BIS has not yet published the results of its investigation.

According to the Presidential Proclamation, the investigation reached an affirmative determination that present quantities and circumstances of copper imports threaten to impair US national security. It found that “global excess capacity for producing copper [is] weakening our economy, resulting in the persistent threat of further closures of domestic copper production facilities and the shrinking of our ability to meet national security production requirements.” BIS transmitted its findings and recommendations to the President in a report on June 30, 2025.

The Presidential Proclamation states that this BIS report recommended that the President impose a 30 percent tariff to address the circumstances threatening to impair US national security. However, the Presidential Proclamation does not explain why a tariff of 50 percent, rather than the 30 percent recommended by BIS, was ultimately imposed on imports of semi-finished copper products and intensive copper derivative products. 

1 Presidential Proclamation of July 30, 2025: “Adjusting Imports of Copper into the United States,” and Fact Sheet: “President Donald J. Trump Takes Action to Address the Threat to National Security from Imports of Copper,” July 30, 2025.
2
CSMS #65794272 – Guidance: Section 232 Import Duties on Copper and Copper Derivative Products, July 31, 2025.
3 See the
list of copper HTSUS tariff codes.
4 “
Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper,” 90 FR 11940 (March 13, 2025).
  

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