Dear Customers, Colleagues, and Friends,
U.S. Customs and Border Protection (CBP) has issued updated guidance under CSMS #68253075 implementing changes to Section 232 duties on steel, aluminum, and copper articles and their derivatives, announced April 3rd and effective April 6, 2026. This update introduces a more structured approach to determining when derivative products are subject to Section 232 duties. CBP has also published a full list of affected HTS classifications. We strongly recommend reviewing this list to determine if your products are impacted:
What’s Happening
Section 232 duties now apply to a broader set of steel, aluminum, and copper derivative products. Duties are now assessed on the full value of the imported article (not just metal content). Duty rates generally range from 10%–50%, depending on classification and conditions. CBP has introduced a more structured framework using Chapter 99 (9903.82.xx) tariff provisions. Goods containing multiple metals are only subject to one applicable duty.
The biggest change here is how CBP is approaching derivative products. If your product’s HTS is on the list, it does not automatically mean duties apply.
The key factor is now metal content by weight:
- “Derivative” products with less than 15% steel, aluminum, or copper content are not subject to Section 232 duties
- Products above that threshold will be subject to section 232 duties, based on classification, C/O, and metal source
Takeaways:
- 15% Rule: Products under 15% metal content are excluded from Section 232
- U.S. metal advantage: Articles made entirely from U.S. melt/pour steel or smelt/cast aluminum/copper are generally subject to 10% duty rates
- UK provisions: Reduced rates may apply to qualifying UK-origin metal products
Standard rates:
- Generally 50% (Annex I-A / Clause 2)
- Generally 25% (Annex I-B / Clause 3)
- Certain goods capped around 15% through 2027 (Annex III)
- Russia: Aluminum articles tied to Russia remain subject to 200% duties
- De minimis: Formalized through the 15% threshold (major simplification)
- Chapter 98 still applies, with some limitations (notably 9802 valuation rules)
- Section 122 (CAA) benefits remain applicable
- Copper: Smelt/cast reporting requirements are expected to be implemented
- Certain previously covered goods (Annex II) are no longer subject
What This Means for You
- Review the attached HTS list and identify any impacted products, expect changing duty implications for your metal imports
- Confirm material composition (by weight) with your suppliers
- Pay close attention to products near the 15% threshold
- Continue to ensure accurate reporting of: Melt & Pour (steel) & Smelt & Cast (aluminum)
**** It is EXTREMELY IMPORTANT to review previous Customer Advisories ( 1/13/26 & 2/4/26) linked here to review the updated tariff refund procedure. We strongly suggest immediately registering for an ACE Portal account, if you haven’t already, and following the ACH REFUND AUTHORIZATION procedure.
Sincerely, Your friends at Krenz and Hannan International