On April 2, 2026, President Donald Trump issued a proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962 authorizes the president to adjust duties on goods imported in quantities or under circumstances that threaten U.S. national security following an affirmative finding from a Department of Commerce investigation.
On February 10, 2025, President Trump imposed Section 232 tariffs on aluminum and steel and their derivative products, later increasing those tariffs to 50% via Proclamation 10947 on June 3, 2025 (see Update of June 5, 2025). On July 30, 2025, he imposed a 50% Section 232 tariff on copper and copper derivative products via Proclamation 10962 (see Update of July 30, 2025).
According to President Trump’s April 2, 2026 proclamation, these updates were necessary because “the Secretary [of Commerce] has informed me that the additional ad valorem duties on imports of metal products are strengthening the American aluminum, steel, and copper industries and addressing the national security threats,” but “that there are opportunities to continue to improve the operation of the tariff regimes.”
Amended Tariff Rates and Scope of the Section 232 Metal Tariffs (Annex I-A and Annex I-B)
The proclamation restructures the application of the Section 232 metal tariffs by dividing covered products across two annexes that carry different duty rates, effective April 6, 2026.
Goods listed in Annex I-A remain subject to the 50% rate established under the Section 232 tariff regimes, while goods listed in Annex I-B are subject to a 25% tariff. For goods covered under the regimes from the United Kingdom, however, reduced rates apply consistent with the bilateral framework deal: Annex I-A goods are subject to a 25% tariff, while Annex I-B goods face a 15% rate.
Articles manufactured abroad but made “entirely” with U.S. metals—i.e., composed of aluminum or copper smelted and cast in the United States, or of steel melted and poured in the United States—are subject to a 10% tariff, regardless of whether the product appears in Annex I-A or Annex I-B.
The proclamation also authorizes the use of manufacturing drawback for goods covered by the Section 232 tariff regimes, provided that specified conditions are met.
All imports of aluminum or aluminum derivatives from Russia, or that contain any amount of primary aluminum smelted or cast in Russia, continue to be subject to the 200% tariff announced in Proclamation 10522, regardless of whether the product is listed in Annex I-A, Annex I-B, or Annex III of the proclamation (see Update of March 3, 2023).
On April 3, 2026, U.S. Customs and Border Protection (“CBP”) issued a clarification in CSMS # 68253075 that “goods specified in the annexes to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76 of the Harmonized Tariff Schedule of the United States (HTSUS), that contain less than 15 percent of the aggregate weight of the applicable metal(s) shall not be subject to the duties imposed by the Proclamation.”
Termination of the Inclusions Process (Annex II)
The proclamation also terminates the derivatives inclusions process established under prior Section 232 proclamations, which relied on periodic Federal Register notices and formal public comment procedures. Before this change, the government had conducted only two rounds of the aluminum and steel inclusions process (see Update of August 18, 2025 (first round) and Update of October 9, 2025 (second round)), while no inclusions process was ever conducted for copper derivatives.
In place of that framework, the Department of Commerce and the Office of the U.S. Trade Representative will now make joint determinations regarding the scope of covered derivative products “on a rolling basis” and “may” solicit input from the public.
Under this revised approach, any inclusion will apply prospectively to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on the date “the Secretary and the Trade Representative make the inquisitive finding or the first practicable effective date after that time, as set forth in a notice in the Federal Register.” The agencies are authorized to reverse prior inclusion determinations too.
In connection with this shift, the proclamation removes several items from the derivatives list, as reflected in Annex II of the proclamation.
Temporary Rate Regime (Annex III)
Additionally, the proclamation establishes a temporary floating tariff framework for goods listed in Annex III of the proclamation, effective April 6, 2026, through December 31, 2027.
Under this framework, a 15% effective tariff cap applies. Where a covered product is subject to a non-duty-free Most-Favored Nation (“MFN”) rate, the Section 232 duty is reduced so that the cumulative duty equals 15%; if the applicable MFN rate exceeds 15%, then only the MFN rate will apply. (For trading partners with whom the United States does not maintain permanent normal trading relations, however, the temporary rate is a flat 25%.)
On January 1, 2028, Annex III will be retired, and the products covered by it will be reclassified under Annex I-B.
Clarifications to the Section 232 Metal Tariffs
The proclamation provides two important clarifications regarding the application of the Section 232 metal tariffs:
- It confirms that the Section 232 tariff applies to “the full customs value of aluminum, steel, and copper articles and their derivatives, regardless of metal content.” This change represents a stark departure from prior guidance issued by CBP, which had indicated that duties should be assessed only on “the total price paid or payable for [metal] content” made (or to be made) by the buyer to, or for the benefit of, the seller.
- The proclamation clarifies that where an article or derivative is potentially subject to more than one Section 232 metal regime, the applicable duties are not cumulative: it should only be subject to a Section 232 metal tariff once, “even if the good contains aluminum and steel, aluminum and copper, steel and copper, or all three metals.”
Next Steps
The proclamation directs the Secretary of Commerce and the U.S. Trade Representative to submit a joint status report to President Trump on the operation of the Section 232 metal regimes within the next 90 days—by July 1, 2026.