Section 232 Just Changed How Your Tariff Is Calculated — Here's What That Means
The short version: the White House changed how Section 232 duties are calculated on steel,aluminum, and copper. The tariff now applies to the full value of your product, not just themetal content. For derivative products, the rate dropped to 25%. And if metal is less than 15%of your product’s total weight, you may owe nothing.
Effective April 6, 2026, importers subject to Section 232 are operating under a completelyrestructured framework. If your product contains steel, aluminum, or copper — and it’s not autoparts, heavy trucks, upholstered furniture, or timber — this applies to you.
What Is Section 232 and Who Does It Cover?
Section 232 of the Trade Expansion Act of 1962 gives the president authority to impose tariffs onimports that threaten national security. In practice, it covers steel, aluminum, and copper articlesand their derivatives. The April 2, 2026 proclamation did not change who is covered. It changedhow the duty is calculated.
Change 1: Full Value, Not Derivative Value
Until the April 2 proclamation, CBP let you declare only the value of the metal content withinyour product. There was a whole ongoing argument about whether you could back out labor andmanufacturing costs from that metal value. That argument is over.
CBP now assesses the tariff on the entire entered value of the product — regardless of whatpercentage of that value is metal.
What this means operationally:
If you import a product worth $10,000 and the steel in it isworth $2,000, you used to pay the tariff on $2,000. You now pay it on $10,000.
Change 2: 25% Instead of 50% for Derivative Products
For derivative products, the rate dropped from 50% to 25%.
Whether this saves you money depends entirely on your product. If the metal content was morethan half the product’s value, the new math works in your favor. If the metal content was a smallfraction of the value, the new full-value base more than offsets the rate reduction — and yourtotal duty bill goes up.
Run the numbers for your specific HTS code before assuming this is a win.
Change 3: The 15% Weight Exemption
If the total metal content of your product — by weight, not value — is less than 15% of theproduct’s total weight, it is fully exempt from Section 232 duties.
Critical point on how “total” is calculated:
If your product contains both steel and aluminum,you add the weight of both metals together. Steel at 10% plus aluminum at 10% equals 20%combined. That product is not exempt. The threshold applies to the aggregate weight of allapplicable metals, not each metal individually.
To claim this exemption, you must report the aggregate metal weight in kilograms as a secondquantity on the entry summary line. Skip that step and CBP will not allow the exemption.
Four Things You Need to Know Before Filing
Tariffs do not stack.
If your product contains both steel and aluminum, you pay one tariff, nottwo. The applicable rate is 25% if it’s a derivative classification.
The 15% weight exemption does not apply to metal-centric chapters.
If your HTSclassification falls in Chapters 72, 73, 74, or 76, the exemption is not available. Those chapterscover iron, steel, copper, and aluminum articles by definition. You pay on full value regardless ofactual metal content.
UK products get preferential rates.
Primary metal articles from the UK are subject to 25%instead of 50%. Derivatives from the UK are subject to 15% instead of 25%. The catch: at least95% of the aluminum must have been smelted or cast in the UK, or 95% of the steel must havebeen melted and poured in the UK. The product being made in the UK is not enough — the metalitself has to qualify.
The US-origin metal exemption is now 10%, not zero.
The prior treatment allowed a fullexemption if the metal was melted, poured, smelted, or cast in the United States. That fullexemption is gone. Products made with qualifying US-origin metal now pay 10%. The 95%threshold still applies.
What to Do Now
Pull the updated HTS code list here. Match your product classifications againstAnnexes I-A, I-B, and II. If you’re in a derivative code, run the full-value calculation and compare
it to what you were paying before. If you’re close to the 15% metal weight threshold, documentthe calculation now before CBP asks for it.
If you have questions about how this applies to your specific product, reach out to your customsbroker before your next shipment arrives.
Simple Forwarding is a licensed US customs broker and freight forwarder. For questions aboutSection 232 classification or entry filing, contact us at
[email protected]
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