Recent changes to Section 232 tariffs on steel, aluminum, and copper are reshaping how importers calculate duties and manage compliance.
Following a new Executive Order, updated tariff rates and rules took effect on April 6, introducing significant changes that will impact cost structures, sourcing decisions, and compliance processes.
Here is what importers need to know.
Key Changes to Section 232 Tariffs
The latest updates introduce several important changes to how tariffs are applied:
- Section 232 tariffs are now based on the full value of the imported product. Non-metal component values can no longer be excluded. This change is particularly impactful for derivative products such as machinery, equipment, and vehicles that contain metal components.
- For example, a product with 20 percent steel content and a $10,000 customs value may have previously been assessed duties on only the metal portion.Under the new rules, the full $10,000 value is subject to Section 232 tariffs, significantly increasing total duty costs.The impact of this change varies depending on the percentage of metal content in a product.
- HTS codes listed in Annex I-A remain subject to a 50 percent tariff. UK steel and aluminum are subject to 25 percent, while copper remains at 50 percent. A new 10 percent tariff applies to US metals.
- HTS codes in Annex I-B are now subject to a 25 percent tariff. UK steel and aluminum are subject to 15 percent, while copper remains at 25 percent. A new 10 percent tariff applies to US metals.
- Items listed in Annex II are no longer subject to Section 232 tariffs.
- HTS codes in Annex III are subject to a 15 percent compound rate through December 2027. After that, the tariff will revert to 25 percent. US metals are subject to a 10 percent compound rate through 2027.
- Importers should plan ahead for this change, as Annex III products will face increased duty exposure after 2027.
- To qualify as UK or US metal, at least 95 percent of the metal must be smelt and cast or melted and poured in that country.
- A new de minimis provision exempts products outside chapters 72, 73, 74, or 76 if the applicable metal content is less than 15 percent of total product weight. Products classified within these chapters are not eligible for the de minimis exemption, regardless of metal content.
This distinction is especially important for steel, aluminum, and copper products, which are often classified within these chapters and therefore remain fully subject to Section 232 tariffs. - If a product does not contain covered metals, the tariff does not apply.
- If a product appears on multiple lists, the tariff is applied only once to the full value.
- The formal inclusion request process has ended, although the Administration may still add products to the lists.
- Section 232 tariffs may now be eligible for manufacturing drawback in certain cases.
- Russian aluminum remains subject to a 200 percent tariff.
Importers should review the Annex lists carefully and validate how these changes impact their current classifications and declared values.
What This Means for Importers
While each regulatory change can be managed individually, the combined impact of tariff updates and refund opportunities is increasing operational complexity. In addition, CBP has increased scrutiny around valuation and documentation, requiring importers to validate declared values and maintain detailed supporting records.
Misclassification or incorrect valuation may increase the risk of penalties as enforcement activity continues to increase.
Compliance teams are being asked to manage multiple priorities at once:
- Reviewing past entries to recover duties
- Ensuring current shipments remain compliant
- Planning for future tariff exposure
Balancing Compliance with Daily Operations
At the same time, they must maintain day-to-day supply chain performance. As a result, many organizations are re-evaluating how they manage trade data, compliance workflows, and internal processes.
Importers that are adapting successfully tend to have:
- Centralized access to entry and shipment data
- Real-time visibility into costs and duty exposure
- Systems that flag tariff changes and compliance risks
- Strong collaboration with compliance and logistics partners
Turning Complexity into Opportunity
Although the current environment is challenging, it also creates opportunities for companies that can respond quickly and strategically.
Organizations that actively manage both refund recovery and tariff changes are not only protecting margins.
They are gaining a competitive advantage through better visibility and faster decision-making.
With the right approach, importers can:
- Identify and recover duties that might otherwise be missed
- Accelerate refund timelines
- Improve cost forecasting and reporting
- Make more informed sourcing decisions
- Strengthen compliance across global operations
A strong compliance partner can help transform a reactive process into a strategic advantage.
Common Questions About Section 232 Tariff Changes
Why did my duty costs increase even if my product contains only a small amount of metal?
Under previous rules, Section 232 tariffs were applied only to the value of the metal content within a product. Now, tariffs are applied to the full value of the imported product, which can significantly increase duty costs even when metal represents a small percentage of the total value.
How do I know which Annex applies to my product?
Annex classification is determined by your HTS code. Importers should review the Annex lists carefully to confirm whether their products fall under Annex I-A, I-B, II, or III.
Are any products exempt from Section 232 tariffs?
Yes. Products listed in Annex II are no longer subject to Section 232 tariffs. In addition, certain products may qualify for exemption if they meet the de minimis threshold based on metal content.
What is the new de minimis rule?
The de minimis provision exempts products that are not classified in chapters 72, 73, 74, or 76 if the total metal content is less than 15 percent of the product’s weight. Products within these chapters are not eligible for this exemption.
How do the new rules impact sourcing decisions?
The updated tariff structure may significantly affect landed costs. Importers should reassess sourcing strategies, particularly when comparing suppliers across different countries or material compositions.
What documentation should importers prepare?
Importers should maintain detailed documentation supporting product valuation, country of origin, and material composition. CBP scrutiny has increased, making accurate records essential for compliance.
Can Section 232 tariffs be recovered through drawback?
In certain cases, Section 232 tariffs may now be eligible for manufacturing drawback. Importers should evaluate whether their operations qualify under current rules.
What should importers do next?
Importers should review their HTS classifications, validate declared values, and assess how the new tariff rules impact their costs and compliance processes.
Working with a trade compliance expert can help reduce risk and improve accuracy.
Stay Current on Section 232 Changes
Section 232 tariff policy continues to evolve, and further updates are likely in the months ahead. Importers should regularly review how these changes impact their classifications, duty calculations, and sourcing strategies.
Auditing broker entries and validating tariff applications can help ensure compliance while minimizing unnecessary costs.
If you need support reviewing tariff exposure, interpreting Annex classifications, or adjusting your compliance strategy, get in touch with the Dimerco Trade Compliance team.
Our experts can help you stay current and make informed decisions in a rapidly changing environment.
