The U.S. Government has recently announced additional changes to the Section 232 tariff program affecting steel, aluminum, copper, and products containing these metals. If your company imports products that contain steel, aluminum, or copper—or imports machinery, equipment, or manufactured goods from Mexico, Canada, or other countries—these changes may impact your duty exposure.
At J.O. Alvarez, Inc., we have been closely reviewing the recent proclamations and monitoring guidance from U.S. Customs and Border Protection (CBP). While some important implementation details are still pending, we wanted to provide an overview of what importers should know today.
https://content.govdelivery.com/bulletins/gd/USDHSCBP-41aa83d?wgt_ref=USDHSCBP_WIDGET_2
In April 2026, the Administration expanded the Section 232 tariff program and established new tariff rates for certain steel, aluminum, copper, and derivative products.
Then, in June 2026, additional modifications were announced that may provide reduced tariff treatment for certain products and introduce new considerations regarding U.S.-origin metal content.
One of the most significant changes is the expansion of the temporary 15% tariff category through December 31, 2027.
Based on the latest proclamation, certain products may qualify for this reduced rate, including:
However, it is important to understand that eligibility is determined by the specific HTS classification listed in the applicable Annexes—not simply by the product description. As a result, companies should review their HTS classifications carefully to determine whether their products may qualify.
Another important development involves products containing U.S.-origin steel, aluminum, or copper.
The recent proclamation reduces the threshold from 95% to 85% U.S.-origin metal content for certain favorable tariff treatment.
Our current understanding is that this requirement refers to the origin of the metal itself—not the percentage of metal contained in the finished product.
For example, a product does not automatically qualify simply because it contains 85% steel. Instead, the steel, aluminum, or copper content itself must generally be of U.S. origin.
At this time, we are still awaiting CBP guidance regarding how U.S. content will be calculated and documented.
The June proclamation also introduces special treatment for certain products imported from Mexico and Canada that qualify under USMCA.
Based on the language currently available, the additional Section 232 duty may be applied only to the non-U.S. content of the product rather than the entire value of the imported merchandise.
However, the proclamation also establishes a minimum effective duty rate of 15%. This means that even if the calculation based on non-U.S. content results in a lower duty amount, the importer may still be required to pay at least a 15% effective duty rate.
While this provision could benefit certain USMCA-qualified products, many questions remain regarding how CBP will calculate U.S. content and administer these provisions.
Although the proclamations establish the overall framework, we are still awaiting formal implementation guidance from CBP.
Some of the key questions include:
We expect additional guidance from CBP and the Department of Commerce in the coming weeks.
We recommend that importers begin reviewing:
Preparing now may help minimize disruptions once CBP releases additional guidance.
Our Compliance Team is actively monitoring CBP announcements, CSMS messages, ACE implementation updates, and additional government guidance related to these tariff changes.
If you would like assistance reviewing your HTS classifications, evaluating potential Section 232 exposure, reviewing USMCA qualification, or assessing how these changes may impact your imports, please contact J.O. Alvarez, Inc. We would be happy to assist.
The information provided above reflects our current understanding of the April and June 2026 Section 232 proclamations. Final applicability, classification, duty assessment, reporting requirements, and eligibility for reduced duty treatment remain subject to U.S. Customs and Border Protection (CBP) interpretation, implementation, and review. Importers of Record remain responsible for ensuring compliance with all applicable customs laws and regulations.
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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.
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
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.
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:
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.
The updated structure includes:
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.
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.
We also expect increased enforcement by CBP, particularly around:
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.
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.
Given these updates, we recommend that our clients:
Our Compliance Team is actively:
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.
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