Big Changes to Tariffs on Steel, Aluminum, Copper and their Derivative Articles

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Apr. 2, 2026
By: Marvin E. McPherson

Have you been seeking advice as to how to calculate derivate articles subject to Sec. 232? Well, don’t lose that advice because you still have a year of liquidating entries to get through. However, going forward, President Trump signed a proclamation on Section 232 and released Tariffs on Steel, Aluminum, and Copper Imports Factsheet, which makes significant changes to the assessment of duties and calculation of imported steel, aluminum, and copper.

From a calculation standpoint, tariffs under Section 232 will be applied solely on the basis of the value of the goods, rather than only the steel (or aluminum or copper) value. This will include derivate articles.

The Proclamation establishes four avenues for Sec. 232 base metals and derivatives, based on the tariff classification of the imported articles;

1. Articles made entirely or almost entirely of aluminum, steel, or copper subject to a flat 50% on their full customs value.
2. Derivative articles substantially made of steel, aluminum, or copper subject to a flat 25% on the entire customs value of the imported product, rather than only the value of the base metal within the derivative articles.
3. Imported items made entirely with American steel, aluminum, or copper subject to a 10% 232 duty.
4. Products made of 15% or less steel, aluminum, or copper will no longer be subject to Sect. 232 metals duties.

Importantly, the EO includes a series of new annexes that establish what articles get what treatment. Importers would be wise to check their articles on the new annexes to ensure they understand the new treatment.

The EO also charges CBP to take action against illegal transshipment, undervaluation, and other tariff evasion methods. All of these are already issues Customs is legally responsible to prevent. The EO also charges CBP to implement smelt and cast information requirements for copper as soon as practicable.

Importers of steel, aluminum, or copper-containing goods should review their tariff exposure based on both finished products and percentage of embedded material content. There is a chance that the goods will not be treated the same under the new 232 regime as under the old, and this could be better or worse.

If you have any questions regarding the best course of action for your company, Contact any attorney  at Barnes, Richardson & Colburn, LLP.