Section 232 metals now hit full customs value, not metal content
The rate change made the headlines. The valuation change did the damage. A derivative article that used to be dutiable on its metal content alone is now dutiable on the whole invoice.
Effective
6 April 2026 for the valuation change, 8 June 2026 for the relief tiers
Legal basis
Section 232 of the Trade Expansion Act of 1962. Proclamation 11021 of 2 April 2026, amended by Proclamation 11032 of 1 June 2026.
What changed
Proclamation 11021, signed on 2 April 2026, took effect at 12:01 a.m. EDT on 6 April. Its central move was not a rate. It was a valuation rule: Section 232 duties on steel, aluminium and copper now apply to the entire customs value of a covered article and its derivatives, regardless of how much metal is actually in it. The previous approach assessed derivative articles on declared metal content alone.
The tiers sit above that rule. Annex I-A carries 50%, covering chapter 72 and most of chapters 73, 74 and 76, the articles made entirely or almost entirely of the metals. Annex I-B carries 25%, covering derivatives substantially made of steel, aluminium or copper, such as pipe fittings and structural components.
Two months later the administration walked part of it back. Proclamation 11032, issued on 1 June 2026 and effective 8 June, created a temporary Annex I-C structure running through 31 December 2027. It sets a 15% transitional rate for metal intensive industrial and electrical grid equipment, a 10% rate for foreign made capital equipment containing at least 85% US origin metal by weight with the steel melted and poured or the aluminium smelted and cast domestically, and preferential 15% treatment for certain products of Argentina, Ecuador, El Salvador, Guatemala, Japan, Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom and EU member states.
It also removed goods outright. Annex II takes derivative articles containing 15% or less steel, aluminium or copper out of scope entirely, which is the single most useful line in the package for consumer goods sellers.
The relief tiers expire. On 1 January 2028 the temporary structure lapses and covered products revert to the Proclamation 11021 rates, so any sourcing decision with a long payback needs testing against the post 2027 numbers rather than against today.
Who it affects
- Furniture sellers. Frames, legs and fixings put a great many items into derivative scope, and the valuation change means duty is now calculated on the upholstered whole rather than on the steel inside it.
- Cookware, hand tool and small appliance importers, where the product is mostly metal and lands squarely in the 50% band.
- Bicycle, fitness equipment and outdoor gear sellers, whose products are metal heavy and who were previously assessed on a metal content declaration.
- Anyone who relied on a metal content calculation to keep an assessment small. For covered goods that method no longer exists.
How settled is this
In force. The 50% and 25% tiers are the baseline. The 15% and 10% relief rates and the country preferences are explicitly temporary and expire on 31 December 2027. The annex lists have been amended twice in three months, so verify against the current annexes rather than against an April summary.
A worked cost example
An importer brings in 300 stainless steel cookware sets landing at $95 each. The set is almost entirely steel, so it falls in the 50% band. The comparison that matters is against the old metal content method rather than against no duty at all.
The rate did not move in that example. The base did, and it cost the importer 20% of the invoice. This is why an April 2026 briefing that only talks about rates will leave a budget badly short.
What importers should do
- 1 Recheck every SKU against the current Annex I-A, I-B and I-C lists and against Annex II. Products have moved between annexes twice since April.
- 2 If a product is 15% or less metal by content, confirm whether Annex II now takes it out of scope entirely. That is the cheapest win available in the whole package.
- 3 Stop maintaining metal content declarations for covered goods as a duty reduction strategy. They no longer reduce the assessment.
- 4 Test long payback sourcing decisions against the rates that resume on 1 January 2028, not against the temporary 15% and 10% tiers.
- 5 For capital equipment, check whether the 85% US origin metal threshold is reachable. The gap between 10% and 25% is worth a supplier conversation.
HS Code Lookup
Identify your subheading first, then check it against the current Section 232 annex lists.
Questions importers keep asking
What actually changed on 6 April 2026?
The duty base. Section 232 tariffs on steel, aluminium and copper began applying to the full customs value of covered articles and derivatives instead of to declared metal content. For a derivative that is almost entirely metal the difference is modest. For one that is half metal by value it nearly doubles the bill.
Are the 15% and 10% Section 232 rates permanent?
No. They were created by Proclamation 11032 effective 8 June 2026 and run through 31 December 2027, after which covered products revert to the Proclamation 11021 rates. Build that reversion into any plan with a payback longer than about eighteen months.
My product is only slightly metallic. Is it still covered?
Possibly not. Annex II removed derivative articles containing 15% or less steel, aluminium or copper from scope entirely. That is a content test applied to a specific list of subheadings, so check both the threshold and whether your code appears on the list.
Does Section 232 stack with Section 301?
Yes. They are separate statutes addressing separate findings. A Chinese origin steel derivative can carry an MFN rate, a Section 301 list rate, the Section 301 forced labour rate and a Section 232 metals rate all at the same time.
Primary sources
Related changes
What to re-check, and when
This page is about the Section 232 metals valuation change, and no published instrument names a closing date for the measure itself, so this site records no scheduled end for it: it runs until the authority behind it revokes or amends it, which is a finding about the measure rather than a gap in the record, while any temporary provision sitting alongside it carries its own date in the passage above that describes it, and what is dated below is the reading rather than the measure.
The claims on this page about the Section 232 metals valuation change were last read on 28 August 2026, against the sources it names, and what to check first is the sentence under this one.
Re-check the annex lists rather than the rates. Products have moved between Annex I-A, I-B, I-C and Annex II twice since April, and that is where the cost surprises come from.
Last verified 28 August 2026 (2026-08-28).