Goods containing 15% or less steel, aluminum, or copper are now fully exempt from Section 232 tariffs under a proclamation President Trump signed Thursday, creating a new content-based threshold that compliance systems must incorporate before the April 6 effective date.

The restructured tariff framework establishes five distinct rate tiers based on metal content and origin, replacing the previous flat-rate approach. Items made "almost entirely" of aluminum, steel, or copper—such as steel coils and aluminum sheets—now face a 50% ad valorem duty. Derivative articles "substantially made" of these metals, including steel cooking appliances, diesel-engine trains, and semi-trailer hauling trucks, incur a reduced 25% rate.

New Section 232 Rate Structure (Effective April 6, 2026):

  • 50% — Goods made almost entirely of covered metals
  • 25% — Derivative articles substantially made of covered metals
  • 15% — Metal-insensitive industrial equipment and electrical grid equipment (through 2027)
  • 10% — Imported goods made entirely with US-origin steel, aluminum, or copper
  • 0% — Goods containing 15% or less steel, aluminum, or copper

The proclamation does not define precise percentage thresholds distinguishing "almost entirely" from "substantially made," creating classification ambiguity that compliance teams must address. The White House fact sheet provides product-level guidance—listing silverware, certain locomotives, and household appliances as derivative articles—but engineering teams will need to implement logic that maps HTS codes to the appropriate tier based on material composition data.

UK Exception: Steel and aluminum products from the United Kingdom receive preferential rates: 25% for items made almost entirely of covered metals (versus 50% standard) and 15% for derivative goods (versus 25% standard). Systems must incorporate country-of-origin logic for UK shipments.

The 15% content exemption threshold introduces a binary classification requirement at the entry level. Compliance systems must now evaluate metal content percentage before applying any Section 232 rate. For goods at or below the 15% threshold, the tariff drops to zero regardless of whether the item previously appeared on derivative product lists covering refrigerators, dishwashing machines, stoves, laundry machines, and microwaves.

The 10% rate for goods manufactured entirely with US-origin steel, aluminum, or copper creates a documentation dependency. Importers must prove domestic metal sourcing to qualify, requiring supply chain traceability that entry systems may need to validate against certificates of origin or mill certifications.

Rate caching implementations face particular risk. The 15% tariff for metal-insensitive industrial equipment and electrical grid equipment expires at the end of 2027, meaning systems must flag these HTS codes for scheduled rate changes. Additionally, Cabinet officials will now add derivative products on a rolling basis rather than through the prior structured review process, requiring more frequent data synchronization.

TradeFacts.io tracks these changes nightly. Start a free 30-day trial.