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On April 2, 2026, President Trump issued a Proclamation modifying the Section 232 tariffs applicable to imports of aluminum, steel, and copper, and derivatives of the same.

Proclamation Provisions

Pursuant to the Proclamation, for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time on April 6, 2026, the Section 232 tariffs on aluminum, steel, and copper, as well as derivative products shall apply as follows:

  • (1) The additional ad valorem rate imposed under Proclamations 9704, 9705, and 10962 Section 232 tariffs shall apply to the full entered value of imported products, “regardless of metal content”
  • (2) The rate will apply to imports of products listed in Annex I-A shall be:
  • (a) 50% unless a lower rate applies pursuant to clause (2)(b) or (2)(c);
  • (b) 25% for United Kingdom products, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the United Kingdom or steel which is composed entirely of steel melted and poured in the United Kingdom; and
  • (c) 10% for derivative articles, composed entirely of aluminum smelted and cast in the United States, the steel content of which is composed entirely of steel melted and poured in the United States, or the copper content composed entirely of copper smelted and cast in the United States;
  • (3) Products listed in Annex I-B shall be subject to the following ad valorem duty rates:
  • (a) 25% unless a lower rate of duty applies under (3)(b)–(3)(c);
  • (b) 15% for aluminum or steel products of the United Kingdom, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the United Kingdom or steel content of which is composed entirely of steel melted and poured in the United Kingdom; and
  • (c) 10% for articles the aluminum content of which is composed entirely of aluminum smelted and cast in the United States, the steel content of which is composed entirely of steel melted and poured in the United States, or copper content of which is composed entirely of copper smelted and cast in the United States
  • (4) The Proclamation also removes the ad valorem duty rates imposed by Proclamations 97704 and 9705 on those goods listed in Annex II.
  • (5) For those goods listed on Annex III, the following rates shall apply until December 31, 2027:
  • (a) The rates shall be determined by the product’s current ad valorem (or ad valorem equivalent) rate of duty under Column 1 of HTSUS as outlined in clause (5) of the proclamation unless a lower rate of duty applies under (5)(b) or a higher rate of duty applies pursuant to (5)(c). For products with a Column 1 rate less than 15% the sum of the Column 1 rate and the additional section 232 rate shall be 15% For a product with a Column 1 rate that is at least 15% the additional section 232 rate shall be 0%.
  • (b) 10% determined based on the product’s current ad valorem (or ad valorem equivalent) Column 1 rate as outlined in (5)(a) for derivative articles the aluminum content of which is composed entirely of aluminum smelted and cast in the United States or steel of which is composed entirely of steel that was melted and poured in the United States; and
  • (c) 25% for products imported from trade partners with whom the United States does not maintain normal trading relations.

Products that are not classifiable under Chapters 72, 73, 74, and 76 of the HTSUS and that do not contain 15% or more aluminum, steel, or copper shall not be subject to the duty rates in the Proclamation.

Subsection 11 clarifies that the Secretary and United States Trade Representative are authorized to include additional derivative articles under the scope if they jointly determine imports of such articles have increased in a manner that threatens national security. Importantly, this section states that the authority “shall allow metal containers to be included in the scope of the metal tariffs, even if they are filled with items that will not be subject to steel, aluminum, or copper tariffs.” Any such inclusions of derivative products shall be announced in the Federal Register.

This Proclamation does not change the effective rate for aluminum imports from Russia. Those remain at 200%.

For those articles containing a combination of metals, only one duty rate shall apply. Goods specified in Annex I-B or Annex III which do not contain any aluminum, steel, or copper, shall not be subject to the duties imposed in subsection (3) and (5).

The Proclamation states it “does not alter or supersede actions implementing any prior agreements” including those with the United Kingdom, European Union, Japan, South Korea, or other trading partners to reduce tariffs imposed under Section 232 on aluminum, steel, or copper articles.

As with previous Section 232 proclamations and executive orders, this Proclamation requires that any products described in subsections (2), (3), and (5) be entered into a foreign trade zone only under “privileged foreign status”.

Manufacturing drawback claims are available if the following conditions are met:

  • The HTSUS is listed in Annex I-B or Annex III or is included in the scope of tariffs at a later date;
  • The article is not subject to antidumping or countervailing duty orders, regardless of whether the article is from the country or countries listed in the order(s);
  • The article is a product of Trade Agreement Partners, which includes the United Kingdom, the European Union, Japan, South Korea, Mexico, Canada and any other trading partner under a final Agreement on Reciprocal Trade; and
  • The article is composed entirely of aluminum smelted and cast in a Trade Agreement Partner country, the steel content is entirely of steel melted and poured in a Trade Agreement Partner country, or copper content is entirely of copper smelted and cast in a Trade Agreement Partner country.

No other drawbacks will be available for duties imposed by this Proclamation.

Importantly, the Proclamation does state that the benefits provided may be revoked for “any trading partner’s products…if the President or the Secretary and the Trade Representative find that imports of derivative articles listed in Annex III…originating from that trading partner have increase in a manner that undermines” United States trade objectives. Any revocation shall be announced through notice in the Federal Register.

Main Takeaways

The Proclamation clarifies as well as changes a number of things about how Section 232 duties on metal products will be applied moving forward. The main takeaways from the Proclamation include:

  • 50% Rate: A flat 50% Section 232 rate on steel, aluminum, and copper of articles in Chapter 72, and a number of goods in Chapters 73, 74, and 76 as listed in Annex I-A.
  • 25% Rate: A 25% Section 232 rate will apply to certain steel, aluminum, and copper derivatives, provided for in Annex I-B.
  • Full Value: If the products are not specifically excluded as listed in Annex-II, the applicable rate will now apply to the full entered value of the goods, rather than the steel, aluminum, or copper content for derivative products as previously allowed.
  • Removal of Certain Derivative HTSUS: a number of goods have been removed from the derivatives list of goods subject to Section 232 duties. The list of products removed from the derivative products list are provided for in Annex II.
  •  15% Rate: products listed in Annex III shall be subject to a temporary 15% rate, inclusive of Most Favored Nation Column 1 rates, until December 31, 2027.
  • Special UK Rates: products that would otherwise be subject to a 50% rate are subject to 25% while derivatives subject to a 25% rate will be subject to 15% if the product originates from the United Kingdom.
  • New De Minimis: products classified outside of Chapter 72, 73, 74, and 76 and listed in Annex IV which do not contain 15% or more metal shall not be subject to Section 232 duties.
  • Manufacturing Drawback: manufacturing drawback shall be available provided the conditions in the Proclamation are met. No other drawbacks are permitted.
  • Product List Can Change: the product list can change at any time, with notices appearing in the Federal Register.
  • No On-the-Water Exception: the effective date for these modifications is 12:01am on Monday April 6, 2026.  There are no exceptions to goods on the water.

This is an evolving situation and additional clarification, in the form of CSMS messages and Frequently Asked Questions, is likely forthcoming. Husch Blackwell’s International Trade and Supply Chain team will continue to monitor and provide updates as they become available.  For specific questions, please contact your Husch Blackwell attorney.