How Section 232 steel, aluminum, and copper duties apply in 2026

TL;DR

• 50 percent on full customs value for steel and aluminum articles and most derivatives, plus most copper articles, on entries from April 6, 2026 forward. The old metal-content valuation method is gone for almost every derivative. Proclamation 11021 (FR Doc 2026-06960) and CBP CSMS 68253075 are the controlling sources.
• Five inputs drive the layer: 10-digit HTS code, country of origin, country of melt and pour (steel) or country of smelt and cast (aluminum), declared customs value, and entry date.
• The Chapter 99 family consolidated April 6, 2026. Steel articles use 9903.81; steel derivatives, aluminum, aluminum derivatives, and most copper articles use 9903.82. The legacy 9903.80 / 9903.85 / 9903.78 codes carry forward only for pre-April-6 entries. Russia aluminum at 9903.85.67/.68 survives the transition.
• 232 stacks with Section 301 and AD/CVD. It does not stack with Section 122. It is not waived by USMCA, KORUS, or any other preference program. The only rate reduction tied to origin is the new US-content carve-out (10 percent on US-melted metal, sometimes 0 percent for derivatives entered under the US-content code).
• The Tandom calculator at tariffs.tandom.ai/calculator picks the right Chapter 99 family for the entry date, applies UK and Russia carve-outs, stacks with 301 and AD/CVD, and cites the regulatory authority on every line.

What changed April 6, 2026

Three changes shipped at 12:01 a.m. ET April 6, 2026, all under Proclamation 11021. Operational guidance is in CSMS 68253075 (April 6, 2026).

1. Full customs value applies to derivatives

Before April 6, 2026, derivative steel and aluminum products outside Chapters 72, 73, and 76 (think hand tools in 82, miscellaneous metal articles in 83, machinery parts in 84, electrical articles in 85, vehicle parts in 87) were dutied at 50 percent on the steel-or-aluminum-content portion of the customs value, not the whole article. The two-line filing pattern (full-value Line 1 with no 9903 code, metal-content Line 2 at quantity zero with the 9903 code) implemented the carve-out.

From April 6, 2026 forward, the 50 percent rate applies to the full customs value for almost every derivative on the Annex I-A list. The metal-content method survives only for the narrow Annex I-B carve-outs at 25 percent and for goods entered under the new US-content code. The two-line pattern is gone for Annex I-A; one line carries the full value at the 50 percent rate.

2. The 9903 code family consolidated

For entries on or after April 6, 2026, the operative metals codes consolidate into the 9903.81 and 9903.82 family:

• 9903.81.x: steel articles (Chapters 72 and 73 covered scope).
• 9903.82.x: steel derivatives, aluminum, aluminum derivatives, and most copper articles and derivatives.
• 9903.85.67 and 9903.85.68: Russia-smelted or Russia-cast aluminum at 200 percent. These survive the consolidation.

The legacy 9903.80 (steel articles), 9903.85 (aluminum), and 9903.78 (copper) families apply only to entries before April 6, 2026. The April 29, 2026 FR Doc 2026-08297 carried HTSUS technical corrections that fixed errors in the April 6 release.

3. Copper derivatives expanded

Copper joined the 232 regime in August 2025 under Proclamation 10962 (FR Doc 2025-14893) with a 50 percent rate on semi-finished copper and intensive copper derivatives effective August 1, 2025. Operational guidance is CSMS 65794272 (July 31, 2025). Proclamation 11021 expanded the copper derivatives list and split it into a 50 percent Annex I-A tier and a 25 percent Annex I-B tier. The legacy 9903.78 family was replaced by the 9903.82 routing on April 6, 2026.

4. US-content code created

For derivatives manufactured entirely with US-melted-and-poured steel, US-smelted-and-cast aluminum, or US-mined-and-refined copper, Proclamation 11021 created a 10 percent rate (in some cases 0 percent for the no-content carve-out). The importer claims the US-content code on the entry summary and supports the claim with a manufacturer attestation. CSMS 68253075 documents the new code structure. The exemption is all-or-nothing per article: a derivative made with imported steel mixed with US steel does not qualify.

5. The pre-April-6 baseline still matters

For entries dated before April 6, 2026, the rate per FR Doc 2025-10524 (the June 3, 2025 doubling proclamation) is still 50 percent on steel and aluminum articles and 50 percent on derivatives, but the derivative duty applied to the metal-content portion only (outside Chapters 72/73/76). Brokers reconciling pre-April-6 entries against post-April-6 entries should expect significantly higher duty on the post-April-6 line for the same product, with no change in HTS classification.

What's covered

Section 232 reaches three categories of products. Each category has its own HTS list, derivative annex, and Chapter 99 code.

Steel articles and derivatives

Authority. Proclamation 10896 (FR Doc 2025-02833) replaced the Trump-1 Proclamation 9705 framework on February 10, 2025, terminated all country exemptions and quota deals as of March 12, 2025, and expanded the derivatives list to roughly 155 product categories. FR Doc 2025-10524 (June 3, 2025) doubled the rate from 25 to 50 percent. Proc 11021 (April 2, 2026) restructured the regime and moved valuation to full customs value for most derivatives.

Scope at a glance. Iron and steel articles in HTS Chapters 72 and 73 (the original Section 232 universe), plus a derivative list reaching into Chapters 82, 83, 84, 85, and 87. The derivative list grew from the original Trump-1 set to roughly 155 product categories under Proclamation 10896 and expanded again in 2025 and 2026 through the BIS Inclusions Process. CBP's official derivative list is maintained by Commerce.

Aluminum articles and derivatives

Authority. Proclamation 10895 (FR Doc 2025-02832) replaced the Trump-1 Proclamation 9704 framework with the same structural reforms as the steel proclamation. Russia-aluminum rules (Proclamation 10522) carry forward.

Scope at a glance. Aluminum articles in HTS Chapter 76, plus a derivative list reaching into Chapters 73 (some welded items), 83 (closures, fittings), 84 (machinery), 85 (electrical), 87 (vehicle parts) and others. The derivative list is published by Commerce and updated through the BIS Inclusions Process.

Copper articles and derivatives

Authority. Proclamation 10962 (FR Doc 2025-14893) imposed a 50 percent tariff on the copper content of semi-finished copper and intensive copper derivatives effective August 1, 2025. Proc 11021 expanded the derivatives list and split it into 50 percent (Annex I-A) and 25 percent (Annex I-B) tiers, and moved valuation to full customs value for most articles.

Scope at a glance. Copper articles in HTS Chapter 74 (refined copper, alloys, semi-finished forms) plus a derivative list including powders, flakes, rods, wires, pipes, and finished electrical components in Chapter 85. Pure copper ore and concentrates are outside scope.

Rates by article and origin

The default rate is 50 percent on full customs value. Country carve-outs and origin reductions sit on top.

The 50 percent default

For entries on or after April 6, 2026, 50 percent ad valorem applies to: aluminum articles, steel articles, most copper articles, and Annex I-A derivatives. Calculated on full customs value, the same value used for the MFN base. No content-portion carve-out for Annex I-A derivatives.

The 25 percent Annex I-B carve-out

A defined subset of derivatives sits at 25 percent rather than 50 percent. The list lives in Annex I-B of Proclamation 11021; BIS and CBP maintain the operational HTS list.

UK rate: 25 percent

Steel and aluminum from the United Kingdom stay at 25 percent rather than 50 percent, under the May 8, 2025 US-UK Economic Prosperity Deal. The melt-and-pour or smelt-and-cast country must be the United Kingdom; UK-shipped but third-country-melted steel does not qualify.

Russia aluminum: 200 percent

Aluminum smelted in Russia, cast in Russia, or whose smelt- and-cast country is unknown carries a 200 percent rate under Proclamation 10522, codified at HTS 9903.85.67 (article level) and 9903.85.68 (derivative level). Effective June 28, 2025, derivative aluminum entered with smelt-and-cast "unknown" pays 200 percent by default. These codes carry forward across the April 6, 2026 consolidation.

US-content carve-out: 10 percent (sometimes 0)

Derivatives manufactured entirely with US-melted-and-poured steel, US-smelted-and-cast aluminum, or US-mined-and-refined copper qualify for a 10 percent rate under a new Chapter 99 code introduced April 6, 2026. A separate code at 0 percent covers derivatives that contain no steel, aluminum, or copper content at all. Both require manufacturer attestation; both fail if any portion of the metal originated abroad.

Melt-and-pour and smelt-and-cast reporting

Two ISO-code fields determine which Section 232 rate applies. Both are filed at the entry summary line level for every line subject to the 232 regime, including derivative lines outside Chapters 72, 73, 74, and 76.

Steel: country of melt and pour

The country where the steel was first solidified into slab, billet, or ingot. CBP's operational guidance is CSMS 64384423 (March 12, 2025), updated periodically thereafter. Reported as a two-letter ISO country code on every Section 232 steel line. Steel melted and poured in the United States (ISO US) is exempt from Section 232 steel duties; the importer reports the ISO code and supports the claim with a mill certificate.

"OTH" is not unknown. CBP uses OTH for cases where no single country can be established (mixed batches, scrap-derived steel where origin is genuinely irreducible). Reporting OTH triggers the 50 percent rate by default. There is no wildcard for "we don't have the data yet"; the entry will not clear without a real ISO code or OTH.

Aluminum: country of smelt and cast

Three ISO codes per line for aluminum and aluminum derivatives: primary country of smelt, secondary country of smelt, and country of most recent cast. CBP's operational guidance is CSMS 64384496 (March 12, 2025).

The Russia rate at 9903.85.67/.68 fires if any of the three values is "RU." If the importer cannot establish smelt and cast, the interim guidance is to report "RU" and pay 200 percent, then file a Post-Summary Correction once the actual countries are confirmed. Effective June 28, 2025, the unknown-default became the 200 percent Russia rate by rule, rather than a discretionary interim measure.

Copper: country of smelting and refining

Copper articles and derivatives carry their own country-of-smelt-and-refine reporting under Proc 10962 and the April 6, 2026 expansion. CSMS 65794272 (July 31, 2025) is the original operational reference; CSMS 68253075 (April 6, 2026) updated the rules to align with the steel-and-aluminum framework. A US-content carve-out exists but, as with the steel-and-aluminum US-content code, requires manufacturer-attested all-US sourcing.

How 232 stacks with 301, 122, and AD/CVD

Section 232 sits in a specific position in the layer stack and interacts with other layers in specific ways.

Stacks with Section 301 (China)

A China-origin steel or aluminum article picks up both Section 232 and Section 301. The two layers add. A 7324.10.00.10 stainless-steel sink from China entered May 1, 2026 carries 3.4 percent MFN, 25 percent Section 301 List 3 (code 9903.88.03), and 25 percent Section 232 steel for an effective rate of 53.4 percent before AD/CVD.

Does not stack with Section 122

The Section 122 surcharge (the IEEPA replacement, 10 percent ad valorem effective February 24, 2026 through July 24, 2026) does not apply to lines that carry Section 232. The Tandom calculator surfaces Section 122 in the line breakout but at zero amount when 232 is active, and applies the non-stacking exclusion code 9903.03.06 automatically. The exclusion is self-executing per the proclamation; no claim required.

AD/CVD applies on top of every layer

Antidumping and countervailing duties are cash deposits at entry under Title VII of the Tariff Act of 1930. They apply regardless of Section 232, Section 301, Section 122, or any preference program. A China-origin sink subject to a future AD/CVD scope ruling would pay the AD/CVD deposit on top of the 53.4 percent already calculated above.

Preference programs do not waive 232

USMCA, KORUS, AGOA, CBI, Israel FTA, and every other preference program reduce or zero the MFN base. None of them waives Section 232. A USMCA-qualifying steel article from Mexico still pays the 50 percent Section 232 if the steel was melted and poured outside the United States. The only origin-based 232 reduction is the new US-content code at 10 percent.

MPF and HMF apply on top

The Merchandise Processing Fee and Harbor Maintenance Fee are user fees, not duties, and apply on top of every duty layer. MPF is 0.3464 percent ad valorem, capped per fiscal year. HMF is 0.125 percent ad valorem on ocean shipments only, no cap. Section 232 does not waive either fee.

Worked example

A stainless-steel sink line from Vietnam, with Taiwan as the country of melt and pour. Numbers come from the Tandom calculator's API output for the inputs below.

Facts.

• HTS: 7324.10.00.10 (Stainless steel sinks with one or more drawn bowls)
• Country of origin: Vietnam (VN)
• Country of melt and pour: Taiwan (TW)
• Steel content: 100 percent
• Entry date: May 1, 2026
• Customs value (transaction value, ex-works, freight and insurance separately stated): $50,000
• Mode: ocean
• No SPI claim, no AD/CVD scope match

Layer-by-layer build. Same shape you would see in the calculator: each line carries an authority badge, the regulatory citation, the rate, and the dollar amount contributed.

Effective rate: 28.4 percent on a $50,000 invoice. Section 232 contributes most of the duty because the sink is a Chapter 73 steel article with non-US melt and pour. Vietnam origin avoids Section 301, and Taiwan-melted steel does not trigger the Russia-aluminum rate. MPF and HMF apply on top. If the same sink shipped China-origin instead of Vietnam-origin, Section 301 List 3 (code 9903.88.03) would add another $12,500 (25 percent), pushing the effective rate to 53.4 percent.

Why Section 232 is 25 percent in this output

The calculator returns the engine's currently configured rate for the entry date. For 7324.10.00.10 entered May 1, 2026, the engine routes through code 9903.82.09 at 25 percent rather than 50 percent. Confirm the live rate against CSMS 68253075 before filing; CBP guidance and the Annex I-A / I-B split control the operative rate, and the calculator's mapping is a working representation of the engine's understanding of the regime, not a substitute for the FR text.

Common pitfalls

The mistakes that bite most often on Section 232 entries:

Filing pre-April-6 patterns post-April-6

The two-line metal-content pattern (full-value Line 1, metal Line 2 at quantity zero) was the right pattern for derivatives before April 6, 2026. After April 6, almost every Annex I-A derivative goes on a single line at full customs value with the 9903.82 code. Brokers carrying forward a saved entry template from March 2026 will undercollect duty by 60 to 80 percent on most derivatives.

Forgetting melt-and-pour on derivatives

Section 232 derivatives outside Chapters 72/73/76 (the cap screws, tools, machinery parts, electrical articles, and vehicle parts in Chapters 82, 83, 84, 85, and 87) require the same country-of-melt-and-pour reporting as raw steel articles. Filing without it triggers a CBP rejection or, after entry, a CBP Notice of Action.

Smelt-and-cast unknown means 200 percent

Effective June 28, 2025, derivative aluminum entered with smelt-and-cast "unknown" pays the 200 percent Russia rate by default. Brokers used to leaving the field blank now produce a 200 percent bill on every aluminum derivative line. Get the smelt-and-cast countries from the manufacturer before quoting.

UK qualifies on melt, not on shipment

The 25 percent UK rate requires the country of melt and pour (steel) or smelt and cast (aluminum) to be the United Kingdom. Steel rolled in the UK from Indian-melted billet does not qualify. The reporting field that controls the 232 rate is melt or smelt, not country of export.

USMCA does not waive 232

A common assumption among importers and forwarders new to the regime: "USMCA waives all duty." It does not. USMCA waives or reduces the MFN base. The 232 layer applies on top regardless of preference-program eligibility. The only origin-based 232 reduction is the new US-content code.

Section 232 product exclusions are gone

Importers carrying old Section 232 product-specific exclusions (the General Approved Exclusions and earlier exclusion requests) cannot rely on them for entries after February 10, 2025. Commerce stopped accepting and stopped processing exclusion requests at 11:59 PM ET that day, per Procs 10895 and 10896. The replacement BIS Inclusions Process can only add derivatives to scope, not remove them.

US-content claims need attestation

The new 10 percent US-content code (and the 0 percent no-content code) require a manufacturer attestation that every gram of covered metal is US-origin. Mixed-melt batches fail. Saving a few percentage points on an unsupported attestation turns into a False Claims Act exposure on audit; the savings are not worth the risk without solid mill-certificate documentation.

OTH is not a wildcard for unknown

OTH is for cases where no single country can be reasonably established (scrap-derived steel where origin is genuinely irreducible, mixed-batch alloys). It is not the field for "we don't know yet." OTH triggers 50 percent, not the carve-out rates. If you are about to file OTH and you have not actually investigated the supply chain, stop and ask the manufacturer.

Stacking errors at the line level

Section 232 stacks with Section 301 (China origin). It does not stack with Section 122. AD/CVD applies regardless. A common quoting error is to apply Section 122 on top of a China-origin steel line that also carries Section 232; the calculator zeros Section 122 automatically, but a manual worksheet that does not handle the non-stacking rule overcollects.

HTS reclassification to dodge the layer

A few importers attempt to classify a steel derivative under a non-Section-232 HTS heading to avoid the 50 percent. CBP audits this aggressively. The derivative HTS list is published by Commerce; misclassification produces a retroactive 232 assessment plus penalty under 19 USC 1592 if the misclassification was not in good faith.

Forgetting that 232 applies regardless of FTZ

Foreign Trade Zone admissions do not avoid Section 232 for consumption entries. The duty is calculated at the time of entry from the FTZ into the US customs territory, using the rate in effect at that time. Pre-positioning steel in an FTZ before a rate increase locks in the FTZ admission date but not the duty rate.

Glossary

Section 232

National-security tariff under 19 USC 1862, originally enacted as part of the Trade Expansion Act of 1962. Authorizes the President to adjust imports of articles found to threaten US national security.

Proclamation 9704 / 9705

Trump-1 proclamations of March 8, 2018 imposing 10 percent (aluminum) and 25 percent (steel) tariffs under Section 232. Substantially replaced by Procs 10895 and 10896 in February 2025.

Proclamation 10895 / 10896

February 10, 2025 proclamations replacing the Trump-1 framework. Terminated all country exemptions and quota deals as of March 12, 2025, expanded the derivatives lists, and eliminated the Section 232 product-exclusion process.

Proclamation 10962

August 5, 2025 proclamation extending Section 232 to copper. 50 percent on the copper content of semi-finished copper and intensive copper derivatives, effective August 1, 2025. Operational guidance: CSMS 65794272.

Proclamation 11021

April 2, 2026 proclamation restructuring the steel, aluminum, and copper regime. Effective April 6, 2026: 50 percent on full customs value of most derivatives (Annex I-A), 25 percent on a smaller carve-out (Annex I-B), 10 percent US-content rate, consolidation of the Chapter 99 family to 9903.81 and 9903.82.

9903.81 / 9903.82

The post-April-6, 2026 Chapter 99 codes for Section 232. 9903.81 covers steel articles; 9903.82 covers steel derivatives, aluminum, aluminum derivatives, and most copper articles and derivatives. Replaced legacy 9903.80 (steel), 9903.85 (aluminum), and 9903.78 (copper) families.

9903.85.67 / 9903.85.68

Russia-aluminum codes at 200 percent under Proclamation 10522. 9903.85.67 covers article-level aluminum; 9903.85.68 covers derivative-level aluminum. Carry forward across the April 6, 2026 consolidation.

Annex I-A

The Proclamation 11021 list of derivatives at the 50 percent rate. Covers most Section 232 derivatives in HTS Chapters 73, 76, 82, 83, 84, 85, and 87.

Annex I-B

The Proclamation 11021 list of derivatives at the 25 percent rate. A narrower list than Annex I-A; the operational HTS list is maintained by BIS and CBP.

Country of melt and pour

For steel, the ISO country code for where the raw steel was first solidified into slab, billet, or ingot. Reported on every Section 232 steel entry summary line. Drives the country-specific Section 232 rates.

Country of smelt and cast

For aluminum, three ISO codes per line: primary smelt, secondary smelt, and most recent cast. Drives the Russia-aluminum 200 percent rate at 9903.85.67/.68.

BIS Inclusions Process

The process that replaced product exclusions in 2025. Allows domestic producers to petition Commerce/BIS to add derivatives to the Section 232 scope. There is no corresponding process for importers to remove a product from scope.

Annex I-A vs metal-content valuation

Before April 6, 2026, derivatives outside Chapters 72/73/76 were dutied at 50 percent on the steel-or-aluminum-content portion of customs value. From April 6 forward, Annex I-A derivatives are dutied at 50 percent on full customs value; metal-content valuation survives only on Annex I-B and the US-content code.

US-content code

The Chapter 99 code introduced April 6, 2026 for derivatives manufactured entirely with US-melted-and-poured steel, US-smelted-and-cast aluminum, or US-mined-and-refined copper. Rate: 10 percent (sometimes 0 percent for no-content derivatives). Requires manufacturer attestation.

OTH

CBP's "other" country code for cases where no single country of melt and pour or smelt and cast can be reasonably established. Triggers the default 50 percent rate. Not a wildcard for unknown.

FAQ

High-intent questions brokers and importers ask most often about Section 232 in 2026.