At J.O. Alvarez, Inc., we want to keep you informed of important regulatory developments that may impact your shipments.

The White House has issued a new proclamation modifying existing Section 232 tariffs on steel, aluminum, and copper, including certain derivative products. These changes are part of ongoing efforts to address national security concerns and strengthen domestic production of critical metals.

https://www.whitehouse.gov/presidential-actions/2026/04/strengthening-actions-taken-to-adjust-imports-of-aluminum-steel-and-copper-into-the-united-states/

CSMS # 68253075 – GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper: https://content.govdelivery.com/bulletins/gd/USDHSCBP-4117593?wgt_ref=USDHSCBP_WIDGET_2

Full-Value Tariff Application

One of the most important updates is that Section 232 duties will now be applied to the full customs value of the imported product, regardless of the actual metal content.

This is a significant change from prior treatment and may result in increased duty exposure, particularly for products that contain steel, aluminum, or copper as a component rather than as the primary material.

HTS-Based Scope Changes

Another key change is that Section 232 applicability is now tied directly to specific HTS codes listed in the official Annexes: https://www.whitehouse.gov/wp-content/uploads/2026/04/Metals-ANNEXES-I-A-I-B-II-III-IV.pdf

This means:

• Some products may now fall under Section 232
• Others that were previously subject may no longer be covered

As a result, it is important that each product is reviewed based on its current HTS classification, as the Annex lists now serve as the controlling reference point.

Updated Tariff Rates

The updated structure includes:

• A general 50% duty for many steel and aluminum articles and certain derivatives
• A 25% duty for certain copper products and other specified derivative goods

Reduced rates may apply in limited cases depending on sourcing, particularly where metals are fully produced in the United States or under certain trade partner conditions.

Changes to Derivative Products

The scope of derivative products has also been revised. Certain items have been removed where they are no longer considered to contribute significantly to national security concerns, while others remain in scope to prevent circumvention.

Additionally, the prior process to request inclusion of derivative products has been eliminated. Going forward, any additions will be made directly by the government on a rolling basis.

Increased Enforcement Expectations

We also expect increased enforcement by CBP, particularly around:

• HTS classification
• Declared value
• Country of origin and metal sourcing

Importers may be required to provide additional information, including where metals are smelted and cast, and CBP has been given expanded authority to address undervaluation and transshipment concerns.

Effective Date

These changes apply to goods entered for consumption or withdrawn from warehouse for consumption on or after:

April 6, 2026 (12:01 a.m. EDT)

As a result, shipments entering next week may be impacted.

What We Recommend

Given these updates, we recommend that our clients:

• Review upcoming shipments, especially those arriving next week
• Confirm HTS classifications at the 10-digit level
• Identify products that contain steel, aluminum, or copper
• Evaluate potential duty impact under the new full-value application

JOA Compliance Team Update

Our Compliance Team is actively:

• Monitoring CBP guidance and CSMS messages
• Reviewing the updated Annex HTS lists

We will continue to keep you informed as soon as CBP provides additional direction.

This update reflects the JOA Compliance Team’s interpretation of the Presidential Proclamation based on currently available information. Final determination of classification, valuation, and duty applicability rests with U.S. Customs and Border Protection (CBP), and implementation details may change pending official CBP guidance.