On April 2, 2026, President Trump issued a presidential proclamation modifying the application of the Section 232 tariffs on steel and steel derivative products, aluminum and aluminum derivative products, and semi-finished copper products and copper-intensive derivative products.1 The proclamation significantly revises the tariffs, especially as applied to derivative products: applying the Section 232 tariffs to the full customs value of the products instead of only to the value of the metal inputs, lowering the tariff rates for certain products that have moderate levels of metal content, adding a few dozen new products to the scope of tariffs, and removing the tariffs from hundreds of products that have low levels of metal content.
The changes take effect for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on April 6, 2026. The proclamation does not provide any exception for goods already in transit to the United States.
New tariff rates and accounting
Tariffs now apply to the full customs value
All tariffs imposed on products under the steel, aluminum, and copper Section 232 actions will now apply to the full customs value of the imported product, including derivative products. The previous system in which the tariffs on derivative products were calculated by splitting the customs value between steel, aluminum, copper, and non-metal content has been eliminated.
The tariffs do not stack with each other
Some derivative products are listed within the scope of more than one of the three Section 232 tariff actions. The proclamation instructs that these products should only pay one of the three tariffs. The steel, aluminum, and copper tariffs will not stack with each other.
Revised tariff rates for steel, aluminum, and copper products
- 50% tariff on steel, aluminum, and copper articles and certain steel and aluminum derivative articles: Articles made entirely or almost entirely of aluminum, steel, or copper are subject to a 50% tariff on their full customs value. These products are listed in Annex I-A of the proclamation. For steel, this generally applies to articles classified within HTSUS chapter 72 and some articles classified in HTSUS chapter 73. For aluminum, this generally applies to articles classified within HTSUS chapter 76. For copper, this generally applies to articles classified within HTSUS chapter 74.
- 25% tariff on steel and aluminum derivative articles and other copper articles: Derivative articles of steel and aluminum and copper articles which are not almost entirely aluminum, steel, or copper are subject to a 25% tariff on their full customs value. These products are listed in Annex I-B of the proclamation.
Reduced tariff rate for using US metal inputs
Copper articles and derivative articles of steel and aluminum on the Annex I-A list and Annex I-B list made with US steel, aluminum, and copper are subject to a 10% tariff instead of the 50% or 25% tariffs. The reduced rate applies to derivative articles for which:
- the aluminum content of the aluminum derivative article is composed of aluminum that was smelted and cast in the United States;
- the steel content of the steel derivative article is composed of steel that was melted and poured in the United States; and
- the copper content of the copper article is composed of copper that was smelted and cast in the United States.
Steel and aluminum derivative products made with inputs from the United States had previously been completely exempted from the Section 232 tariffs.
Temporary tariff reduction for certain derivative products
Certain steel and aluminum industrial equipment and electrical grid equipment are subject to a temporarily reduced tariff rate of the higher of either (1) a 15% Section 232 tariff or (2) the normal Column 1 MFN rate. If these products are made from US steel, aluminum, or copper inputs, they are subject to a temporarily reduced tariff rate of the higher of either (1) a 10% Section 232 tariff or (2) the normal Column 1 MFN rate. These products are listed in Annex III of the proclamation.
On January 1, 2028, the tariff reduction will expire, and these products will be subject to the 25% tariff under the Annex I-B list (or the 10% tariff level for products using US inputs), which stacks with any applicable MFN tariff.
Products originating in countries with which the United States does not have normal trading relations do not qualify for this tariff reduction (i.e., Belarus, Cuba, North Korea, and Russia). The proclamation also notes that the Trump administration reserves the right to revoke this tariff reduction for other countries.
United Kingdom special rates for steel and aluminum
President Trump has committed to negotiating an exception from the steel and aluminum tariffs for products from the United Kingdom (UK). While those negotiations progressed in 2025, President Trump exempted UK products from the increase in the tariffs from 25% to 50% that he proclaimed in June 2025. That preferential treatment is retained as part of the April 2, 2026 revisions, but with new origin criteria. To qualify for the special UK rates, the aluminum content must be aluminum that was smelted or most recently cast in the UK and the steel content must be steel that was melted and poured in the UK.
Under the revised system:
- UK steel and aluminum products that otherwise would have been subject to the 50% tariff (the Annex I-A list) are instead subject to a 25% tariff.
- UK steel and aluminum products that would otherwise have been subject to the 25% tariff (the Annex I-B list) are now subject to an alternative 15% tariff.
Russian aluminum remains subject to the alternative 200% tariff
All imports of aluminum articles and aluminum derivatives listed in Annex I-A and Annex I-B (and Annex III) that are the product of Russia, or for which any amount of primary aluminum used in the manufacture of these articles is smelted or cast in Russia, remain subject to the 200% tariff established in Proclamation 10522 of February 24, 2023.
Product removals and exceptions
Derivative products removed from the scope of the tariffs
The proclamation completely removes certain steel and aluminum derivative products from the scope of the Section 232 actions. These products are listed in Annex II of the proclamation.
Unless otherwise excepted, these products will become subject to the global 10% Section 122 tariff, which is currently in effect until July 24, 2026.
Covered products excepted from the tariffs
The proclamation provides several new opportunities to claim exceptions from the Section 232 tariffs for products that would otherwise still be covered:
- De minimis exception: A tariff exception applies to certain derivative products for which the aggregate weight of the applicable steel, aluminum, and copper inputs is less than 15% of the total weight of the imported product. Any product that is not classifiable within HTSUS chapters 72 (iron and steel), 73 (articles of iron and steel), 74 (copper and articles thereof), and 76 (aluminum and articles thereof) may qualify for this de minimis exception.
- Exception for products that do not contain steel, aluminum, or copper: Products on the Annex I-B and Annex III lists that do not contain any steel, aluminum, or copper are exempt from the tariffs.
- Motorcycle parts exception: Parts imported for use in manufacturing motorcycles and classifiable within HTSUS chapters 84, 85, and 87 are exempt from the steel, aluminum, and copper Section 232 tariffs.
- Civil aircraft and parts exceptions for certain trade deal countries: In President Trump's Agreements on Reciprocal Trade with the UK, European Union, South Korea, and Japan, the administration committed to excepting civil aircraft and parts from the steel, aluminum, and copper Section 232 tariffs. The proclamation maintains those exceptions.
Other customs details
New country of smelt and cast reporting requirement for copper
The proclamation instructs US Customs and Border Protection (CBP) to establish a new requirement for importers of covered copper products to report the countries in which their copper inputs were smelted and cast. Similar requirements already exist under the steel and aluminum Section 232 actions.
Foreign trade zone entry
Articles entered into a US foreign trade zone (FTZ) on or after April 6, 2026 may be admitted only under "privileged foreign status" (except those eligible for admission under "domestic status"); "and any products admitted in 'privileged foreign status' prior to the effective date of this proclamation will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTSUS subheading."
Limits to duty drawback
Manufacturing drawback claims under 19 U.S.C. § 1313(a)-(b) are allowed for products on the Annex I-B list (or Annex III) if (1) the article is not subject to antidumping or countervailing duty orders, and (2) the article is a product of the United Kingdom, the European Union, Japan, the Republic of Korea, Mexico, Canada, or any trading partner with which the United States concludes a final Agreement on Reciprocal Trade (ART) and was smelted and cast (if aluminum), melted and poured (if steel), or smelted and cast (if copper) in these countries. No other drawback claims are available.
Chapter 98 eligibility
Covered imports are eligible to claim entry under the provisions of HTSUS chapter 98, except that duties under HTSUS subheading 9802.00.60 are assessed based on the full customs value of the article.
Curtailment of the derivative product "inclusions process"
The previous "inclusions process" for steel, aluminum, and copper derivative products is terminated by the proclamation. However, the Department of Commerce and Office of the United States Trade Representative (USTR) may still add new steel, aluminum, and copper products to the scope of the tariffs through an alternative, internal process discussed in the proclamation. If added to the scope of the tariff actions, a product would be subject to either the Annex I-A 50% tariff or the Annex I-B 25% tariff, depending on the nature of the product.
For further information regarding this report or international trade matters, please contact any of the partners or senior attorneys listed below from White & Case’s Global International Trade Practice.
1 Presidential Proclamation of April 2, 2026: “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, And Copper into the United States.” For the technical annexes and lists of products, see the link to Annexes I-A, I-B, II, III & IV.
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