If you learned how Section 232 metal tariffs work before April 2026, what you learned is outdated. A presidential proclamation signed April 2 — effective April 6 — replaced the entire calculation method, not just the rates. This matters more than a typical rate adjustment: it changes what portion of a product's value the tariff actually applies to.
The old system, briefly, so you know what changed
Before April 6, Section 232 tariffs on derivative products (finished goods that incorporate steel, aluminum, or copper alongside other materials) applied only to the metal-content portion of the product's value. A steel appliance with a plastic housing would owe the tariff on the steel's value, with the non-metal portion outside Section 232's reach entirely.
The current system: full customs value, tiered by metal content
That split no longer exists. Per the proclamation's own text, the additional Section 232 duty now applies to the full customs value of the imported product, regardless of metal content — once a product falls within scope, the tariff isn't prorated by how much of it is actually metal.
Whether a product falls within scope, and at what rate, depends on tiers:
- 50% — articles made entirely or almost entirely of steel, aluminum, or copper (raw materials like steel coils, aluminum sheet).
- 25% — derivative articles substantially made of these metals, per the specific HTSUS classifications listed in the proclamation's annexes.
- 15% — certain metal-intensive industrial and electrical grid equipment, through the end of 2027 (a temporary reduced rate meant to support US industrial buildout).
- 10% — derivative articles where the metal content is US-origin (originally requiring 95% US-origin content, lowered to 85% in a June 2026 revision).
- Excluded entirely — products where the applicable metal makes up 15% or less of total weight fall outside Section 232 altogether, unless separately listed.
The practical shift: under the old system, a composite product's non-metal value was never exposed to Section 232, no matter what. Under the current system, if your product's metal content clears the relevant threshold, the entire customs value — including the non-metal portion — is subject to the duty. There's no partial exposure anymore; it's effectively all-or-nothing per product, determined by which tier it falls into.
One more mechanical detail worth knowing
Where a specific product appears in more than one of the proclamation's annexes, the additional duty applies only once — it isn't cumulative across overlapping listings. And if you're storing covered products in a Foreign Trade Zone, they now need to be admitted under "privileged foreign status" specifically, with duty drawback availability significantly more restricted than before.
Why this matters beyond just steel and aluminum importers
This same full-value, threshold-based approach is the version of Section 232 that later actions — including the Section 338 Canada tariffs and the new Section 301 forced-labor action — are built to interact with when determining exclusivity. If you're checking whether your composite product avoids a second tariff layer because "only part of it is metal," that logic no longer applies the way it used to. Check which tier your product falls into first — that determines whether Section 232 covers the full value or none of it, not a proportional split.
This reflects the April 2, 2026 proclamation (effective April 6, 2026) and its June 2026 revision, verified directly against the proclamation text — not legal or customs advice. Metal-content percentage calculations and annex classifications are genuinely technical; confirm your specific product's tier and applicable rate with a licensed customs broker before relying on any figure above.