Effective April 6, 2026, Section 232 tariffs on steel, aluminum, and copper will apply to the full customs value of imported goods rather than the metal content value alone. This valuation methodology change, announced via Administrative Proclamation, fundamentally alters duty calculations for any HTS classification containing covered metals.
The new framework introduces a four-tier rate structure based on metal composition:
- 50% on articles made entirely or almost entirely of aluminum, steel, or copper (e.g., steel coils, aluminum sheets)
- 25% on derivative articles substantially made of these metals
- 15% on metal-intensive industrial and electrical grid equipment (expires 2027)
- 10% on products manufactured abroad using American-origin steel, aluminum, or copper
The shift from metal-content-only to full customs value creates significant duty exposure increases. A product previously assessed Section 232 duties only on its steel component value will now face tariffs calculated against the entire declared customs value—a change that could multiply effective duty rates for mixed-material goods.
New De Minimis Threshold: Products containing 15% or less steel, aluminum, or copper content by value are now exempt from Section 232 metals tariffs. Annex II of the proclamation specifically references furniture-related HTS codes eligible for this exemption.
For trade compliance engineering teams, this update requires immediate attention to HTS classification logic and rate caching systems. The April 6, 2026 effective date means any automated duty calculation that references Section 232 rates must account for both the new tiered structure and the valuation base change. Systems calculating duties on metal content value alone will return incorrect results after the effective date.
Implementation Note: The 15% tariff tier for metal-intensive industrial and electrical grid equipment includes a 2027 sunset provision. Rate tables and API responses should flag this expiration to prevent compliance gaps when the tier terminates.
The de minimis exemption at the 15% metal content threshold creates a binary classification requirement: products must be assessed for their steel, aluminum, and copper composition to determine whether Section 232 applies at all. Annex II contains the specific HTS codes qualifying for this exemption, including multiple furniture-related classifications. Compliance systems should cross-reference product HTS codes against Annex II entries before applying any Section 232 rate.
The 10% rate tier for American-metal products manufactured abroad introduces origin documentation requirements into the Section 232 calculation. This tier requires verification that constituent metals are U.S.-origin, adding a data dependency beyond standard HTS classification.
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