Update on Section 232 Tariff Changes on Steel, Aluminum & Copper

We’re pleased to share the following message from our Board Member, Steve Zisser:

The White House announced on April 2, 2026, significant new Section 232 measures affecting steel, aluminum, and copper. These changes took effect Monday, April 6, 2026, immediately following the holiday weekend, leaving limited time for importers to assess impact and take action.

Based on currently available information, our initial understanding is outlined below:

Key highlights:

New tariff rates:
Tariffs will now apply to the full value of the imported product, rather than only the metal content
50% - Products listed in Annex I-A (generally goods made entirely of metal; Chapters 72, 73, 76)
25% - Products listed in Annex I-B (certain goods Chapters 72, 73, 76; Chapters 84, 85, 90, etc.)
Effective Date: Monday April 6, 2026
Duties are not stackable – if a product appears on multiple lists, it will only be assessed once.

New De minimis Exemption:
Products containing less than 15% metal content by weight may qualify for exemption
Applies only to products classified outside of chapter 72, 73, 74, and 76

Preferential UK Rates:
25% - Annex I-A products that are Products of the UK 
15% - Annex I-B products that are Products of the UK
To qualify for these rates, at least 95% of the steel must be melted/poured in the UK, or 95% of the aluminum must be smelted/cast in the UK

US Melt/Pour and US Smelt/Cast Provision:
Now limited to certain steel, aluminum, and copper derivatives
Products with at least 95% US melt/pour (Steel) or US smelt/cast (aluminum or copper) are subject to 10% duty

Drawback:
Manufacturing drawback is allowed (subject to conditions)
No other drawback is allowed

Russia 200% (Continued):
Aluminum products tied to Russia (including unknown smelt/cast origin) remain subject to 200% duties
If the smelt/cast is unknown, it will continue to be subject to 200%

Additional Adjustments:
Certain products have been removed from tariff coverage (see Annex II)
A temporary 15% tariff cap applies to specified industrial and electrical equipment through 2027

What This Means
These changes represent a major shift in how Section 232 duties are calculated, particularly due to the move to full value assessment, which may substantially increase duty exposure. At the same time, new exemptions, caps, and preferential treatments may create strategic planning opportunities.

Recommended Next Steps
We strongly recommend that importers immediately review:
Product classifications
Valuation methodologies
Country of origin determinations (melt/pour, smelt/cast)
Supply chain structures

We Are Available
Given the urgency and magnitude of these changes, our team is available to assist with rapid impact assessments and planning.

For assistance or any further questions please contact Zisser Group at solutions@zissergroup.com