Products exempt from section 232

The April 2, 2026 proclamation did not just restructure Section 232 rates — it removed hundreds of products from coverage entirely. Bicycles and e-bikes are out. Filled food and beverage cans are largely out. Empty metal containers are still in. And the process that allowed industries to petition for exclusions has been shut down.

If you think your product might be exempt, you need to check the annexes — not assume.

What Got Removed from Section 232 Coverage

The April 2 proclamation included Annex II, which pulled a significant number of HTS codes out of Section 232 scope altogether. Products removed from coverage are no longer subject to the 50% or 25% rates. They become subject to whatever other applicable duties exist — currently the Section 122 global surcharge of 10%.

The removals are concentrated in two categories: products packaged in metal containers (filled food, beverages, chemicals, pharmaceuticals, soaps) and certain finished goods where the administration determined the metal tariff was not achieving its intended purpose.

This is not a blanket exemption for anything in a metal package. The relief is specific to the HTS codes listed in Annex II. If your code is not on that list, you are not exempt.

Bicycles and E-Bikes: Fully Removed from Section 232

The bicycle and e-bike industry fought this one for months. Two petitions were filed — one by Guardian Bikes and one by the Aluminum Extruders Council — seeking to add bicycle HTS codes to the Section 232 derivative list and impose a 50% tariff on the metal content of all bikes and frames. The industry mobilized over 1,300 comments in opposition.

The result: bicycles and e-bikes were not added. And under the April 2 proclamation, complete bicycles and e-bikes in their core HTS categories are not subject to Section 232 at all.

What this does not mean: It does not mean all bicycle-related products are clean. Chains, cables, and certain components have been in scope previously. The exemption covers complete bikes in the core HTS categories. If you are importing parts, check each code individually against the annexes.

The Bicycle Exemption Is Not Permanent

This is worth understanding clearly. The bicycle industry’s win was not granted as a formal product exclusion with an exclusion code. It was accomplished by removing the relevant HTS codes from the annexes entirely.

That distinction matters. The proclamation gives the Secretary of Commerce and the US Trade Representative joint authority to add derivative products back to the covered list on a rolling basis — at any time, without a formal petition process. There is no exclusion code to monitor, no renewal date, no public comment period required before the codes get added back.

The exemption exists today. It could be gone in a future Federal Register notice.

The Petition Process Is Gone

The prior inclusion process — which allowed US manufacturers to petition Commerce to add competitor products to the Section 232 derivative list — has been terminated. No new petition windows will open. The two pending petitions that were not acted on were effectively denied by the proclamation.

Going forward, changes to the covered product list will be made directly by Commerce and USTR, without the formal petition-and-comment structure. This is a significant shift. Industries that previously had a clear process for seeking coverage or challenging it no longer have that mechanism.

The practical effect: expect the covered product list to change without much advance notice. Watch Federal Register notices.

How to Check If Your Product Is Exempt

The operative document is the HTS list attached to CSMS 68253075. Cross-reference your Chapter 1–97 classification against each annex:

• Annex I-A: Subject to Section 232 at 50% (25% for UK-qualifying products)
• Annex I-B: Subject to Section 232 at 25% derivative rate
• Annex II: Removed from Section 232 coverage
• Annex III: Transitional reduced rate through December 31, 2027

When in doubt, pull the full annex text and confirm the classification with your broker before the shipment arrives.

Simple Forwarding is a licensed US customs broker and freight forwarder. For questions about Section 232 product coverage or HTS classification, contact us at [email protected]